# F I N A L

Finding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1

F o r m e r M a r i n e C o r p s A i r S t a t i o n
E l T o r o , C a l i f o r n i a

July 2012

Base Realignment and Closure Program Management Office West 1455 Frazee R oad, Suite 900 San Diego, California 92108

Prepared under: 

### Naval Facilities Engineering Command Contract Number N6 2473

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- 5001 DCN: ECS

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### TABLE OF CONTENTS

i 

### ACRONYMS AND ABBREVI ATIONS i ii

1. PURPOSE 1

2. PROPERTY DESCRIPTION 1

3. REG ULATORY COORDINATION 1 3.1 Resource Conservation and Recovery Act Part B Permit and Subtitle C Corrective Action 2 3.2 Resource Conservation and Recovery Act Subtitle I Corrective Action 3 3.3 Comprehensive Environmental Response, Compensation, and Liability Act 3

4. SUMMARY OF ENVIRONME NTAL CONDITIONS AND NOTIFICATIONS 4 4.1 CERCLA/RCRA 4 4.1.1 Carve

- Ou t II

- F

- 1 (Figure 3) 5 4.1.2 Carve

- Out II

- Q (Figure 4) 5 4.1.3 Carve

- Out II

- V

- 1 (Figure 5) 6 4.2 Petroleum Products and Derivatives 6 4.2.1 Carve

- Out II

- F

- 1 (Figure 3) 6 4.2.2 Carve

- Out II

- Q (Figure 4) 6 4.2.3 Carve

- Out II

- V

- 1 (Figure 5) 7 4.3 Asbestos

- Containing Material 7 4.4 Lead

- Based Paint 7 4.5 Poly chlorinated Biphenyls 8 4.5.1 Carve

- Out II

- Q (Figure 4) 8 4.6 Pesticides 8

5. SUMMARY OF RESTRICTI ONS 9 5. 1 Petroleum Products and Derivatives 9 5.1.1 Carve

- Out II

- Q (Figure 6) 9 5.2 Asbestos

- Containing Material 9 5.3 Lead

- Based Paint 9

6. ADJACENT PROPERTIES 10

7. COVENANTS 10

8. ACCESS CLAU SE 11

9. FINDING OF SUITABILI TY TO TRANSFER 11

10. REFERENCES 12Contents

ii 

### TABLES

1 Buildings/Structures

2 Environmental Requirements and Notifications

3 Potential Release Locations

4 Locations of Concern

5 Summary of Asbestos Surveys

6 Monitoring Wells



### FIGURES

1 Vicinity Map

2 Carve

- Out Area s Location Map

3 Carve

- Out I I

- F

- 1

4 Carve

- Out I I

- Q

5 Carve

- Out II

- V

- 1

6 Carve

- Out II

- Q Existing Buildings/Structu res and Wells



### ATTACHMENTS

1 Comments/Response to Comments

2 Unresolved Comment s

3 Agency Correspondence

4a Hazardous Substances Notification Table

4b Petroleum Products Notification Table

### ACRONYMS AND ABBREVIATIONS

iii 

### ACM asbestos

- containing material APHO aerial photograph feature/anomaly AR PR area requiring petroleum restrictions AST aboveground storage tank

BNI Bechtel National, Inc. BRAC Base Realignment and Closure

C ABACO/Tait CABACO/Tait Environmental Management, Inc. CCR California Code of Regulations CERP Covenant and Environmental Restriction on Property CFR Code of Federal Regulations

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CO carve

- out

DERP Defense Environmental Restoration Program
DoD United States Department of Defense DON United States Department of the Navy DTSC California EPA/ Department of Toxic Substances Control

e&e Ecology and Environment EBS Environmental Baseline Survey

FAD friable, accessible, and damaged

FFA Federal Facility Agreement FIFRA Federal Insecticide, Fungicide, and Rodenticide Act FOST Finding of Suitability to Transfer

HSC Health and Safety Code

IRP Installation Restoration Program
IT Corp. International Technology Corporation

JP5 jet propulsion fuel, grade 5

LBP lead

- based paint LLC Limited Liability Corporation LOC location of concern

MCAS Marine Corps Air Station MNA monitored natural attenuation MSC Miscellaneous

NFA no further action NFI no further investigation NPL National Priorities List

OCHCA Orange County Health Care Agency

### ACRONYMS AND ABBREVI ATIONS

iv 

### OU Operable Unit OWS oil/water separator

PCB polychlorinated biphenyl

ppm parts per million PRG Preliminary Remediation Goal
PRL potential release location

RACR Remedial Action Completion Report RCRA Resource Conservation and Recovery Act RFA RCRA Facility Assessment
RI Remedial Investigation ROD Record of Decision RWQCB California Regional Water Quality Control Board, Santa Ana Region

SVOC SWMU semi

- volatile organic compounds solid waste management unit

TAA temporary accumulation area TFA truck fueling area

U.S. United States U.S.C. United States Code U.S. EPA United States Environmental Protection Agency UST underground storage tank

VOC volatile organic compoundFinal Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

1 

### 1. PURPOSE
The purpose of this Finding of Suitability to Transfer (FOST ) #7 is to summarize how the requirements and notifications for hazardous substances, petroleum products, and other regulated material within Carve

- Outs (COs) I I

- F

- 1, II

- Q, and II

- V

- 1 at former Marine Corps Air Station (MCAS) El Toro have been satisfied by the United States Department of the Navy (DON). T hrough the Base Realignment and Closure (BRAC) process, the DON transferred, by deed(s), certain former MCAS El Toro real property in 2004. Other real property known as COs w as retained by the DON, pending further investigation and cleanup to support determinations that the property is environmentally suitable for transfer. This FOST #7 was prepared in accordance with the Department of the Navy Base Realignment and Closure Program Management Office P olicy for Processing Findings of Suitability to Transfer or Lease (BRAC 2008), Base Redevelopment and Realignment Manual ( United States D epartment of Defense [DoD] 2006), and is consistent wi th the DoD Base Redevelopment and Implementation Manual (DoD 1997).

2. PROPERTY DESCRIPTION
Former MCAS El Toro is located in central Orange County, California (Figure 1) and was operationally closed in July 1999

. The property proposed for transfer under this FOST #7 consists of 3 CO s comprising approximately 1 5 0

. 281 acres

. T able 1 presents a summary of the existing remaining buildings and structures within the CO s

. Figure 2 is a base

- wide map that provides the location s of the CO s

. A brief description of the CO s follows:

 

### CO II

- F

- 1 (Figure 3)

– consists of approximately 26. 45 9 acres located in the east

- central portion of the former S tation and contains no buildings or structures. The DON leased this CO to Heritage Fields, Limited Liability Corporation (LLC), who has subsequently assigned the lease for the majority of this CO to the City of Irvine.

 

### CO II

- Q (Figure s 4 & 6 )

– consists of approximately 8 3

. 70 2 acres located in the central portion of the former S tation and contains B uild ings 114, 124, 125, 126, 127, 230, 231, 363, 372, 642, 658, 677, 698, 716, 747, 752, 763, 779, 903, 923, 938, 952, and 1804. CO II

- Q also contains structures 396, 558, 559, 560, 561, 659, 904, 905, 906, 907, 908, 909, 910, and 911. The DON leased this CO t o Heritage Fields, LLC, who has subsequently assigned the lease for the majority of this CO to the City of Irvine.

 

### C O II

- V

- 1 (Figure 5)

– consists of approximately 40. 12 0 acres located along the eastern edge of the former S tation and contains no buildings or struct ures. The DON leased this CO to Heritage Fields, LLC, who has subsequently assigned the lease to the City of Irvine.

3. REGULATORY COORDINAT ION

F ormer MCAS El Toro was listed on the U.S. Environmental Protection Agency ( U.S. EPA) National Priorities List (NPL) under the Comprehensive Environmental Response, Compensation, and Liability Act ( CERCLA ) in February 1990

. The Defense Environmental Restoration Program (DERP), codified as 10 United States Code (U.S.C.) Sections 2701

– 27 09, gave the DoD Environmental Restoration Program a statutory basis

. The DON implements the DERP subject to, and in a manner consistent with

, CERCLA and its regulations.

In October 1990, U.S. EPA Region 9 , State of California Department of Health Services ( now referred to as California EPA/ Department of Toxic Substances Control [ DTSC ] ), California Regional Water Quality Control Board , Santa Ana Region ( RWQCB ) and the DON signed a Federal Facilit y Agreement (FFA) ( DON 1990)

. The U.S. EPA, DTSC

, and RWQCB were notified of theFinal Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

2 

### initiation of this FOST #7 and were issued copies for review

. Regulatory agency comments to this FOST #7 are provided in Attachment 1, and unresolved comments are provided in Attachment 2.

3.1 R ESOURCE 

### C ONSERVATION AND 

### R ECOVERY 

### A CT 

### P ART 

### B P ERMIT AND 

### S UBTITLE 

### C C ORRECTIVE 

### A CTION



### This FOST #7 reviews sites that were evaluated and addressed under the DON ’s CERCLA and DERP authority as well as sites addressed under the corrective action requirements of the Resource Conservation and Recovery Act (RCRA) Subtitle C (for s olid w aste m anagement u nits [SWMUs])

, RCRA Subtitle I (for underground storage tanks [ USTs ] ) and associated state laws and regulations administered by the U. S. EPA, the State of California

, and the County of Orange

. These corrective action authorities are similar to CERCLA in that they require response/corrective action (cleanup) where necessary to ensure adequate protection of human health and the envir onment

- s ee Section 121(d) of CERCLA, Health and Safety Code (HSC) Section 25296.10(b), Title 23 California Code of Regulations (CCR) Sections 2720 (definition of “corrective action”) and 2725(c), and Title 22 CCR Section 66264.101(a).

A decision that no action i s required in order to protect human health and the environment, made by the DON or an environmental regulator under th e laws and regulations listed above , also supports a DON determination under Section 120(h) of CERCLA that all remedial action necessary to protect human health and the environment with respect to any such substance remaining on the property has been taken

.

F ormer MCAS El Toro was subject to a RCRA Part B permit that was issued in June 1993 and expired on 18 Augus t 2003

. The permit addressed one regulated unit (Building 673

- T3) as well as RCRA corrective action requirements for SWMUs

. The RCRA permit incorporated the FFA (referred to as the “Agreement”) for MCAS El Toro by reference and provided, in relevant part:

“ The activities required by the Agreement are intended to satisfy the corrective action requirements of RCRA Section 3004(u) and (v), and 42 U.S.C. Section 6924(u) and (v)

. The Agreement and any schedules contained therein are hereby incorporated by refere nce as the schedule for completing corrective action at the facility...” (Subsection V.A.1 of the permit)

. The FFA itself specifically requires that RCRA corrective action requirements be addressed in the FFA process

- s ee subsections 1.1(b), 1.2(e), 3.1, 17 .1, 17.2, 17.3, and 19 of the FFA ( DON 1990).

The rationale for integrating CERCLA and RCRA corrective action requirements in this fashion is straightforward

. The cleanup standard for CERCLA is set forth in Section 121 of CERCLA ( Cleanup Standards ) , which states in the relevant part of Subsection 121(b)(1): “...The President shall select a remedial action that is protective of human health and the environment...” (42 U.S.C. Section 9621(b)(1))

. The cleanup standard for RCRA Subtitle C corrective action in the State of California

, as set forth in Title 22 CCR Section 66264.101(a)

, provides : “The owner or operator of a facility seeking a permit for the transfer, treatment, storage, or disposal of hazardous waste shall institute corrective action as necessa ry to protect human health and the environment for all releases of hazardous waste or constituents from any solid or hazardous waste management unit at the facility, regardless of the time at which waste was placed in such unit.” A lso see HSC Sections 251 87 and 25200.10(b).

In a letter dated 8 March 1996, DTSC concurred with no further action (NFA) for Building 673

- T3 and stated that the p erm it was terminated based on the Closure Certification Report that was submitted by the DON (DTSC 1996 a )

. The DON cont inues to complete all RCRA Part B permit corrective actions for the SWMUs under the FFA executed in 1990

.Final Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

3 

### DTSC has not made a RCRA Corrective Action Complete Determination for the property associated with this FOST # 7

. However, DTSC has reviewed the Navy's FOST #7 and concurs that the subject property is suitable for transfer in a manner that is protective of human health and the environment

. See attached letter s from DTSC to transferee(s) dated 30 July 2012 and 2 August 2012 (Attachment 3).

3.2 R ESOURCE 

### C O NSERVATION AND 

### R ECOVERY 

### A CT 

### S UBTITLE 

### I C ORRECTIVE 

### A CTION



### The Orange County Health Care Agency ( OCHCA ) and the RWQCB administer the UST corrective action program at former MCAS El Toro pursuant to RCRA Subtitle I and Section 25280

- 25299.8 of the California HSC

. The authority of OCHCA and the RWQCB to require corrective action at UST sites is set forth at Title 23 CCR , division 3

, c hapter 16.

These regulations specifically define “corrective action” as “...any activity necessary to investigate and analyze the e ffects of an unauthorized release; propose a cost

- effective plan to adequately protect human health, safety, and the environment and to restore or protect current and potential beneficial uses of water; and implement and evaluate the effectiveness of the a ctivity(ies)...” (Title 23 CCR Section 2720)

. Furthermore, Section 2725(c) of the regulations sets forth requirements for

c orrective a ction p lans prepared by responsible parties and states that : “The regulatory agency shall concur with the c orrective a ction p lan after determining that implementation of the plan will adequately protect human health, safety, and the environment and will restore and protect current or potential beneficial uses of water.”

NFA letters issued by the RWQCB and OCHCA are in accordanc e with Section 2721(e) of the regulations listed above which provides : “Upon completion of required corrective action, the regulatory agency shall inform the responsible party in writing that no further work is required at that time, based on available inf ormation.”

HSC Section 25296.10(a) provides that the State Water Resource s Control Board “...shall develop corrective action requirements for health hazards and protection of the environment based on the severity of the health hazards and the other factors l isted in subdivision (b) ...” HSC Section 25296.10(b) provides : “Any corrective action conducted pursuant to this chapter shall ensure protection of human health, safety, and the environment.”

The corrective action cleanup standard for USTs implemented by the RWQCB and OCHCA are codified in HSC Section 25296.10(b), Title 23 CCR 2720 (definition of "corrective action") and Title 23 CCR 2725(c) (soil and water investigation phase, corrective action plan)

. While DTSC h as not made a RCRA Corrective Action Complete Determination for the property associated with FOST #7, DTSC has reviewed this FOST #7 and concurs that the property is suitable for transfer in a manner that is protective of human health and the environment

. DTSC has issued a letter to the transferee(s) clarifying the corrective action obligations for property associated with this FOST #7, including property that was investigated and cleaned up under the oversight of the RWQCB and the OCHCA (Attachment 3).

3.3 C OMPREHENSIVE 

### E NVIRONMENTAL 

### R ESPONSE 

### , C OMPENSATION 

### , A ND 

### L IABILITY 

### A CT


### CERCLA response actions are initiated at environmental sites where CERCLA hazardous substances have been or may have been released

. There are two such areas known as Installation Res toration Program ( IRP ) sites in this FOST #7

. CERCLA response actions have been completed at two IRP Site s : 4 and 25, as noted in Section 4.1

.Final Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

4 

### 4. SUMMARY OF ENVIRONME NTAL CONDITIONS AND NOTIFICATIONS

This s ection summarizes the environmental conditions and notifications as they relate to CERCLA and RCRA, petroleum products and derivatives, asbestos

- containing materials (ACM), lead

- based paint (LBP), and /or other regulated materials

. Pursuant to 40 Code of Federal Regulations (CFR) Part 373, the d eed(s) f or the CERCLA

- impacted CO s will contain a notice of hazardous substances stored, released, or disposed of, if any, within the CO

. This notice is provided in Attachment 4 a , the Hazardous Substances Notification Table

. Attachment 4 b, the Petroleum Products Notification Table, lists the locations of concern ( LOCs ) associated with the storage of petroleum products only.

Table 2 identifies the environmental requirement s and notifications applicable to the COs

. Based on an evaluation of the MCAS El Toro E nvironmental B aseline S urvey (EBS) of September 2003 (Earth Tech 2003), hazardous substances, petroleum products, CERCLA

, and RCRA response actions, storage tanks, oil/water separators (OWSs), ACM, LBP

, and polychlorinated biphenyls (PCB s) were present or have occurred within the COs

.
The EBS identified several facilities/features as being associated with a potential release of contaminants in to the environment

. These locations were first identified during the preparation of the 2003 EBS, and are labeled potential release locations ( PRLs )

. Subsequently, the FFA signatories agreed that the DON would prepare investigation plans, perform field evaluations, and provid e conclusions as to whether a PRL needed to be included in a specific regulatory clean

- up program, or whether no further investigation (NFI) was warranted

. Table 3 and Table 4 identif y and provide the status of the PRLs within the C O s as indicated on F igur e 4

. Bas ed on additional records reviews and soil sampling

, it was determined that no significant release of hazardous substances or pollutants has occurred; therefore, NFI is warranted at the following PRLs:

 

### CO II

- Q

– PRL 1 14 (DTSC 2005 a , U.S. EPA 2005 a ), PRL 235 (DTSC 2009 a ), PRL 372 (DTSC 2009 a ), PRL 658 (DTSC 2005a, U.S. EPA 2005a), PRL 716 (DTSC 2009 a ), PRL 747 (DTSC 2009 a ), and PRL 923 (DTSC 2005 b , U.S. EPA 2005 b ).
A petroleum release was identified at PRL 127, and PRL 127 is discussed in Section 4 .2.2. Table 4 identifies LOCs within the COs

. LOCs are areas where a release is suspected to have occurred, a documented release has occurred, or based on the types of activities that occurred in the area, there was a potential for a release

. The types of LOCs present within the COs include: hazardous substance sites, RCRA Facility Assessment (RFA) sites, temporary accumulation areas (TAAs), aerial photograph feature/anomaly (APHO) sites, IRP sites, aboveground storage tanks ( ASTs )

, USTs, OWSs, miscellaneou s (MSC) sites

, PRL site s , and PCB

- containing transformers and equipment

. The LOC s within the COs proposed for transfer ha ve received r egulatory agenc y

concurrence for NFA with the exception of ongoing petroleum corrective actions for groundwater at : 1 ) UST 398 within CO II

- Q , and : 2 ) MSC jet propulsion fuel, grade 5 ( JP5 ) pipelines and associated

t ruck f ueling a reas (TFA s ) within CO II

- Q

. These sites with ongoing petroleum corrective actions for groundwater ha ve received vadose zone soil NFA closure from the RWQCB , but will transfer with restrictions as noted in Section 5.1

. NFA designations are based on the findings of evaluations or cleanup actions that these LOCs are suitable for transfer as long as the applicable notifications and

res trictions outlined in Section s 4 and 5 respectively are adhere d to

. This includes LOCs that meet the federal and state definitions of SWMUs and received NFA designations either because no corrective action was required to provide adequate protection of human health and the environment, or the required corrective action has been completed.

4.1 CERCLA/RCRA
The following CE RCLA/RCRA sites within the COs received closure and NFA

. Site closure actions are detailed in Table 4.Final Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

5 

### 4.1.1 Carve

- Out I I

- F

- 1 (Figure 3 )

There are no CERCLA/RCRA LOCs within CO II

- F

- 1.

4.1. 2 Carve

- Out II

- Q (Figure 4 )

APHO Sites

– APHO 25 received site closure concurrence ( DTSC 1999 a , U.S. EPA 1999

, RWQCB 2000 a ). AP HO 50 received site closure concurrence ( DTSC 1999 b , RWQCB 2000 a ). APHO 9 8

r eceived site closure concurr ence ( DTSC 2004 a , RWQCB 2003 a ). APHO 100 received site closure concurrence (DTSC 2003 a , RWQCB 2003 a ).

IRP Sites

IRP Site 4 : IRP Site 4 is located immediately southeast of Building 658, a former jet

- engine testing facility. The S ite is bounded by 9th Street to the south, Building 658 to the north and west, and Tank Farm No. 5 to the east. IRP Site 4 consists of two units: Unit 1 is an oil

- stained area southeast of Building 658 which overlaps a co ncrete transformer pad, and Unit 2 is a drainage ditch which received runoff from a ferrocene spill.

The staining at Unit 1 was the result of oily discharges from Building 658, which were observed over an approximate 2

- year period. The contamination at Unit 2 originate d from an August 1983 spill, when the contents of a 500

- gallon tank (wash water and residual jet fuel) reportedly overflowed during washing and spilled onto the ground, draining into a ditch adjacent to 9th Street. The spilled liquid reportedly contained approximately 5 gallons of ferrocene and a hydrocarbon carrier solution.

Investigations conducted at IRP Site 4 include a Phase I Remedial Investigation ( RI ) and aerial photograph surveys in 1993. Volatile organic compounds ( VOCs ) and semi

- volatile organic compounds (SVOCs) were below residential Preliminary Remediation Goals ( PRGs ) in both U nits

. The human health and ecological risk assessments showed that the contaminants present in the soil do not present an unacceptable risk to human health or the environment. Therefore, no remedial action was required. The NFA Record of Decision ( ROD ) was signed on 30 September 1997 (DON 1997).

During the RI for I RP Site 4, groundwater monitoring wells were installed near Building 658 and a

re lease of petroleum to groundwater was detected. This release was attributed to jet fuel released from the nearby JP5 pipelines at the former JP5 TFA; the petroleum

- impacted groundwater is known as the JP5 TFA Plume. The RWQCB has approved closure of the va dose zone soil for the MSC JP5 pipeline segments and TFA features overlying the plume. An evaluation of natural attenuation of groundwater was completed in 2007, and the RWQCB concurred with monitored natural attenuation (MNA) with long

- term monitoring as the groundwater remedy on 31 August 2007. The DON is conducting groundwater monitoring of the JP5 TFA Plume in accordance with the MNA remedy as required by the Monitored Natural Attenuation Evaluation and Long

- Term Monitoring Plan, Former
JP

- 5 Truck Fueli ng Area, Former Marine Corps Air Station, El Toro, California (Wiedemeier & Associates 2007). Figure 6 shows the location of the JP5 TFA Plume

, and Section 5.1 summarizes restrictions related to petroleum products and its derivatives

.

IRP Site 25 . IRP Site 25 comprises Agua Chinon Wash, Bee Canyon Wash, Borrego Canyon Wash, and Marshburn Channel that flow through former MCAS El Toro. Three of these drainages (Agua Chinon Wash, Bee Canyon Wash, and Borrego Canyon Wash) are continuations of natural washes that originate in the Santa Ana Mountains. Surface drainage from the hills and upgradient irrigated farmland combines with runoff generated from extensive paved surfaces at former MCAS El Toro. The on

- S tation storm water system dis charges to the dra inage channels, which in turn flow into San Diego Creek. San Diego Creek discharges into upper Newport Bay, about 7 miles downstream fromFinal Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

6 

### its intersection with Marshburn Channel. The portion of IRP Site 25 addressed in this FOST #7 is Agua Chinon Wash whic h traverses CO II

- Q

.

IRP Site 25 include s drainages that ha d the potential to contaminate regional groundwater. The S ite was formed before the source of the regional VOC groundwater contamination had been identified at IRP Site 24. The S ite was identified for a Phase II RI, but the drainages were investigated as part of the Phase I RI for Sites 18 and 24 to evaluate the source of the off

- site VOC groundwater plume. Potential contamination within the major drainages and San Diego Creek was assessed by analy zing surface water, sediment, soil

, and soil gas samples. Except for the Borrego Canyon Wash, metals and pesticides were detected above former MCAS El Toro background concentrations in all drainages. The human health and ecological risk assessments showed that the contaminants present in these media do not present an unacceptable risk to human health or the environment. Therefore, no remedial action was required. The Draft Final RI Report was completed in 1997 ( Bechtel National,
Inc . [ BNI ] 1997), and the IRP Site 25 Final ROD for NFA was signed on 30 September 1997 ( DON 1997 ).

RFA Site s

– RFA 13 received site closure concurrence ( DTSC 1996 b ). RFA 15 received site closure concurrence ( DTSC 1996 b ). RFA 16 received site closure concurrence ( DTSC 199 6 b ). RFA 40 received site closure concurrence ( DTSC 1996 b ). RFA 41 received site closure concurrence ( DTSC 1996 b ). RFA 210 received site closure concurrence (DTSC 1996 b ). RFA 257 received site closure concurrence (DTSC 1996 b ). RFA 258 received site closure concurrence (DTSC 1996 b ).

TAA Sites

– TAA 658 received site closure concurrence (DTSC 2004 b )

. TAA 698 received site closure concurrence (DTSC 2004 c )

. TAA 779 received site closure concurrence (DTSC 200 4 d ).

4.1. 3 Carve

- Out II

- V

- 1 (Figure 5 )

There are no CERCLA/RCRA LOCs within CO II

- V

- 1

. 4.2 P ETROLEUM 

### P RODUCTS AND 

### D ERIVATIVES


### The corrective action cleanup standards for petroleum USTs implemented by the RWQCB and OCHCA are codified in HSC Section 25296.10(b), Title 23 CCR 2720 (definition of "corrective

ac tion") and Title 23 CCR 2725(c) (soil and water investigation phase, corrective action plan)

. Site closure actions are detailed in Table 4.

4. 2

. 1 Carve

- Out I I

- F

- 1 (Figure 3 )
There are no petroleum related LOCs within CO II

- F

- 1.

4. 2

. 2 Carve

- Out I I

- Q (Figure 4 )

ASTs

– AST 126 received site closure concurrence ( RWQCB 2011 a )

. AST 372 received site closure concurrence ( RWQCB 2000 b ). AST 658 received site closure concurrence (DTSC 2003 b ).

USTs

- UST 114 A received site closure concurrence (RWQCB 199 7 a )

. UST 114B received site closure concurrence (RWQCB 199 9 a ). UST 114C received site closure concurrence (OCHCA 2004). UST 126 received site closure concurrence (RWQCB 199 6 ). UST 204 received site closure concurrence (RWQCB 2003 b ). UST 205 and UST 207 received site closure concurrence (OCHCA 1998 a ). UST 206 received site closure concurrence (RWQCB 2008). UST 208, UST 209, UST 211, UST 213, and UST 215 received site closure concurrence (OCHCA 1997 a ). UST 210 , UST 212, and UST 214 received site closure concurrenc e (OCHCA 1996). UST 372A received site closure concurrence (OCHCA 2000 a ). UST 372B received site closure concurrence ( RWQCB 1995 ). UST 398 received NFA concurrence for vadose zone soil (RWQCB 2011 b ) ; h owever, the petroleum groundwater plume associated with UST 398 is part of an ongoing petroleum corrective action. TheFinal Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

7 

### area requiring petroleum restrictions ( ARPR ) for UST 398 is shown on Figure 6 and the restrictions are listed in Section 5.1. UST 658A and UST 658B recevied site closure concurrence (OCHCA 199 8 b ). UST 716A received site closure concurrence (OCHCA 1998 c and RWQCB 1999 b ). UST 763B received site closure concurrence (OCHCA 2000 b ). UST 902A, UST 902B, and UST 902C received site closure concurrence (OCHCA 2000 c ). UST T

- 6 received site closure concurr ence (OCHCA 1997 a ). UST T

- 7 and UST T

- 8 received site closure concurrence (OCHCA 2000 d ). UST
T

- 9 received site closure concurrence (OCHCA 1997 b ).

OWSs

– OWS 6 58C and OWS 658D received site closure concurrence (RWQCB 2003 c ). OWS
6 58E received site closure concurrence ( RWQCB 2003 d ). OWS 7 16 B received site closure concurrence ( OCHCA 199 8c and RWQCB 1999 b ). OWS 763A received site closure concurrence ( OCHCA 2000 b ).

PRL Site

– A petroleum release was identified and evaluated at PRL 127, and the RWQCB concurred with no further action (RWQCB 2009).

MSC Site s

– The portions of MSC JP5 pipelines with associated TFA within CO II

- Q received vadose zone soil closure concurrence (RWQCB 2011 c ) , h owever, the petroleum groundwater plume associated with the MSC JP5 pipelines and associated TFA is part of an ongoing petroleum corrective action. The ARPR is shown on Figure 6 and the restrictions are listed i n Section 5.1.

4.2.3 Carve

- Out I I

- V

- 1 (Figure 5 )
There are no petroleum related LOCs within CO II

- V

- 1.

4. 3 A SBESTOS



### - C ONTAINING 

### M ATERIAL


### It is DoD policy to manage ACM in a manner protective of human health and the environment, and to comply with all applicable federal, state, and local laws and regulations governing ACM hazards (D o D 1994)

. Therefore, unless it is determined by a competent authority that ACM on the property poses a threat to human health at the time of transfer, all property containing ACM will be conveyed, leased, or otherwise disposed “as is” through the BRAC process

. If ACM in a building does pose a threat to human health or the environment, occupation of the building will be prohibited until the ACM is abated or the building is demolished by a transferee

. Remediatio n of ACM is not required in buildings that are scheduled for demolition by the transferee.

Buildings require a survey if they have never been surveyed for ACM; non friable, accessible , and damaged ( FAD ) ACM was detected in a survey that was conducted prior to but not since 1997 (i.e., not within the last three ( 3 ) years of S tation operation) or they were surveyed for FAD ACM only and therefore, the presence of non

- FAD ACM is unknown.

There are a total of 2 3 non

- residential buildings and 1 4 structure s wi thin CO II

- Q

. A total of 17 non

residential buildings within CO II

- Q have been surveyed and the coating on a segment of the MSC JP5 pipeline within CO II

- Q has been sampled for ACM. I nformation on the existence, extent, and condition of ACM at these buildings and structure s is provided in Table 5

.

4. 4 L EAD


### - B ASED 

### P AINT


### Notification of potential LBP at buildings and structures is based on the age of construction (i.e., constructed before the Consumer Product Safety Commission’s 1978 ban on LBP for residential use)

. CO II

- Q contains buildings and structures that were constructed prior to 1978 and, therefore, suggests the likelihood that LBP may be present. This in turn creates the possibility that, through the action of normal weathering and maintenance, there may be lead from LBP in the soil surroundingFinal Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

8 

### these buildings and structures . Construction dates for each of the buildings and structures in CO II

- Q are summarized in Table 1. There are no buildings or structures located in CO II

- F

- 1 or CO II

- V

- 1.

Demolition of non

- residential buildings and structures constructed prior to 1978 creates the possibility of lead being found in the soil as a result of such activities. With respect to any such non

residentia l buildings and structures which the transferee intends to demolish and redevelop for residential use after transfer, the transferee may, under applicable law or regulation, be required by DTSC or other regulatory agencies to evaluate the soil adjacent to such non

- residential buildings and

structures for soil

- lead hazards, and to abate any such hazards that may be present after demolition of such non

- residential buildings and structures , and prior to occupancy of any newly constructed residential buildings.

There are no residential buildings or structures associated with FOST #7 . N o LBP surveys were conducted for buildings and structures associated with FOST #7. See Section 5.3 for restrictions.

4. 5 P OLYCHLORINATED 

### B IPHENYL S



### The DON has investigated potential releases of PCBs into the environment pursuant to its CERCLA authority and did not identify any such releases that required CERCLA remedial action. Therefore, all necessary remedial action to address PCB releases has been taken.

Ballasts in fluorescent light fixtures made prior to 1979 may contain sealed PCB

- containing components. A comprehensive survey at the former Station for PCB

- containing light ballasts has not been conducted ; however , it is assumed that buildings, structure s, and facilities constructed prior to 1979 have PCBs in the ballast of older light fixtures. It should be noted that many buildings that were constructed prior to 1979 have had interior renovations and new light fixtures installed that do not contain PCBs

.
Fluorescent light ballasts manufactured before 1979 often contain PCB capacitors

. No action is required at buildings, structures , and/or facilities unless large quantities of PCB

- containing fluorescent light ballast s are r emoved. According to DON guidanc e on the disposal of fluorescent light ballasts containing PCBs (DON 1989), when a large quantity of PCB capacitors needs to disposed, they should be handled as regulated PCB equipment. Fluorescent light ballasts that contain PCBs have approximately 1.0 to 1.5 ounces of PCB fluid in each capacitor. There are approximately 3.1 to 4.7 pounds of PCB fluid for every 50 PCB small capacitors in fluorescent light ballasts. The transferee may, under applicable laws and regulations, be required by DTSC or other regu latory agencies to address disposal of light fixtures if they remove them following transfer of the property.

4.5. 1 Carve

- Out II

- Q (Figure 4 )

Transformers PCB T14, T20, T21, T58, T60, T89, and T94 within CO I I

- Q w ere replaced with a

non

- PCB transformer and no evidence of a release has been identified at these transformer locations (DTSC 2003 c and U.S. EPA 2003). Transformer PCB T109 was removed during UST excavation activities related to former Tank Farm 6 (DTSC 2003c and U.S. EPA 2003), and no evidence of a release has been identified at this transformer location. Non

- transformer PCB items with less than 10 parts per million ( ppm ) PCB concentrations were associated with Buildings 208 and 372. NFA was received at these non

- transformer PCB locations (DTSC 2003c and U.S. EPA 2003).

4. 6 P ESTICIDES



### The transferee is hereby notified that the property may contain pesticide residue from pesticides that have been applied in the management of the property. The DON knows of no use of any registered pesticide in a manner inconsistent with its labeling and believes that a ll applications were made in accordance with the Federal Insecticide, Fungicide, and Rodenticide Act ( FIFRA) (7 U.S.C. SectionFinal Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

9 

### 136, et seq.), its implementing regulations, and according to the labeling provided with such substances. It is the DON position that it shall have no obligation under the covenants provided pursuant to Section 120(h)(3)(A)(ii) of CERCLA , 42 U.S.C. Section 9620(h)(3)(A)(ii), for the remediation of legally applied pesticides.

5. SUMMARY OF RESTRICTI ONS

This s ection summariz es restrictions , if any, related to petroleum products and derivatives, ACM, and /or LBP

. These restrictions ensure that post

- transfer use of the CO areas is consistent with protection of human health and the environment

.

5. 1 P ETROLEUM 

### P RODUCTS AND 

### D ERIVATIVES



### 5. 1. 1 Carve

- Out II

- Q (Figure 6 )

Former UST 398 and MSC JP5 pipeline s with associated TFA

– Former UST 398 and MSC JP5 pipeline s with associated T FA are part of an ongoing petroleum corrective action related to groundwater. Therefore, land use restrictions for these petroleum plume areas will be incorporated into and implemented through two separate legal instruments: (1) a quitclaim deed between the DON and the transferee and (2) a Covenant and Environmental Restriction on Property (CERP) (here inafter referred to as the RWQCB Covenant) between the DON and the RWQCB

.
In order to limit the exposure to petroleum and its derivatives and to maintain the integrity of the corrective action until the corrective action is complete, the RWQCB Covenant wil l restrict the following activities within the ARPR as shown on Figure 6 without prior review and approval from the DON and R W QCB:

 

### Any activity that causes or facilitates the movement of known contaminated groundwater ;

 

### Alteration, disturbance, or removal o f any component of a corrective action, including but not limited to

, groundwater monitoring wells (Table 6 ) and associated equipment

, or associated utilities ;

 

### Extraction of groundwater and installation of new groundwater wells ; and

 

### Removal of or damage to security features (for example, locks on monitoring wells, survey monuments, fencing, signs, or monitoring equipment and associated appurtenances).

5. 2 A SBESTOS



### - C ONTAINING 

### M ATERIAL


### The transferee will be required to comply with the specific restrictions l isted below for ACM that has been identified within CO

- II

- Q. Information on the existence, extent, and condition of ACM at buildings

, structures , and MSC JP5 Pipelines with in CO II

- Q is provided in Table 5.

Except for short

- term tours and emergency mainten ance, access, use, or occupancy is prohibited pending either (1) completion of ACM surveys and completion of any necessary ACM abatement by the transferee or (2) demolition by the transferee, in accordance with all applicable local, state, and federal laws and other requirements relating to asbestos or ACM. Pending completion of abatement or demolition, the transferee shall ma nage the ACM in accordance with all such applicable local, state, and federal laws and requirements. This restriction is applicable to all buildings

, structures , and MSC JP5 Pipelines located within CO II

- Q.

5. 3 L EAD


### - B ASED 

### P AINT


### In its use and occupancy of the property, including, but not limited to: demolition of buildings, structures, and identification and/or evaluation of any LBP h azards, the transferee shall beFinal Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

10 

### responsible for managing LBP and LBP hazards in accordance with applicable federal, state, and local laws, and other requirements relating to LBP and LBP hazards.

Non

- residential buildings and structures constructed prior to 1978 (Table 1) may not be used for residential use or child

- occupied buildings and structures unless the transferee performs any necessary evaluation(s) and abatement in accordance with all federal, state, and local laws and other applicable requirements. This restriction applies to all buildings and structures located within CO
II

- Q (Table 1)

.

6. ADJACENT PROPERTIES

T he COs in this FOST #7 are primarily adjoined by property previously transferred under the MCAS El Toro FOST of July 2004 ( DON 2004)

, or subsequent FOSTs

. A r eview of all the available information

, including review of records from the RWQCB Geotracker website

, as well as DTSC EnviroStor website

, indicate no known sources of contamination on the adjoining properties

. However, t he COs are also adjacent to COs remaining under DON that requir e additiona l remediation a s described below

.

CO II

- Q is adjoined to the northeast by CO II

- D (Figure 2 )

. CO II

- D includes IRP Site 3, Original Landfill. The Final ROD (DON 2008) documents the final selected remedy for soil and NFA for groundwater. The final selected remedy for soil includes a landfill cap, landfill gas monitoring and control system, groundwater monitoring, and institutional controls . Construction activities are complete and the landfill remedy is in place. The landf ill remedy has achieved the Remedial Action Objectives specified in the Final ROD. As such, a Draft Remedial Action Completion Report ( RACR ) has been issued which also documents th at the S ite is protective of human health and the environment.

CO II

- F

- 1 ad joins DON

- retained CO II

- F

- 2 and CO II

- F

- 3. The CO II

- F

- 3 is associated with former Tank Farm 555 area petroleum corrective action related to groundwater undergoing MNA (Figure 2)

. The CO II

- V

- 1 adjoins DON retained CO II

- V

- 2 which is associated with IRP Site 1 and IRP Site 2 groundwater plumes undergoing remediation (Figure 2). Buffer zones within the retained COs are sufficient for contain ing the plumes and protect COs II

- F

- 1 and II

- V

- 1

.

7

. COVENANTS

The deed for transfer of CO II

- V

- 1 on which there has been no release or disposal of hazardous substances or petroleum products or petroleum derivatives, and for which required regulatory concurrence as to such status has been obtained, will include a covenant made pursuant to CERCLA Section 120(h)(4)(D)(i). Such covenant will warrant that any response action or corrective action found to be necessary after the date of transfer shall be conducted by the U.S. This covenant shall not apply to any response action or corrective action required on the CO that is a result of an act or omission of the transferee.

The dee d for transfer of CO II

- Q and CO II

- F

- 1 on which “any hazardous substance was stored for one year or more, [or] known to have been released, or disposed...” as a result of former activities conducted by the U.S., will include a covenant made pursuant to CERCLA Section 120(h)(3)(A)(ii) and (B ). The covenant will warrant that all remedial action necessary to protect human health and the environment with respect to any hazardous substance remaining on the p roperty has been taken before the date of transfer and that “any additional remed ial action found to be necessary after the date of such transfer shall be conducted by the United States.” This covenant will not apply to any remedial action required on CO s that is the result of an act or omission of the transferee that causes a new release of hazardous substances.

## ( T HIS 

## P AGE 

## L EFT 

## I NTENTIONALLY 

## B LANK



## )Final Finding of Suitability to Transfer #6 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

12 

### 1 0

. REFERENCES

Base Realignment and Closure Program Management Office. 2008. P olicy for Processing Findings of Suitability to Transfer or Le ase . December.

Bechtel National, Inc. (BNI). 1997

. Draft Final Phase II Remedial Investigation Report OU

- 3A Sites . Marine Corps Air Station El Toro, California. March

.

CAB A CO/Tait Environmental Management, Inc. (CAB A CO/Tait). 1999a. Asbestos and Lead Survey Report, MCAS, El Toro, California. October 15.

______. 1999b. Asbestos and Lead Survey Report, MCAS, El Toro, California. June 15.

______. 1999c. Asbestos and Lead Survey Report, MCAS, El Toro, California. July 22.

California Department of Toxic Substances Control (DTSC). 1995. Concurrence Letter for Environmental Baseline Survey, Marine Corps Air Station, California . April 1995.

______. 1996 a

. Letter. Acceptance of Closure Certification: Hazardous Waste Storage Area (Building 673

- T3) Marine Corps Air Station El Toro, Santa Ana, California (EPA ID No. CA 6170023208) . March.

______. 1996b. Final RCRA Facility Assessment (RFA) Approval: Marine Corps Air Station (MCAS) El Toro . July 23.

______. 1999a. No Further Acti on Concurrence for APHO 25

. August 31

.

______. 1999b. No Further Action Concurrence for APHO 50. November 30.

______. 2003a. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) Sites 83, 85, 87, 89, 90, 91, 95, 100, 102, 104, 108, 109 , 112, 114, 116, 117, 119, 123, and 124. June 25.

______. 2003b. No Further Action Concurrence Letter for Above Ground Storage Tank (AST) 658

. March 10

.

______. 2003 c

. Concurrence with the Final Environmental Baseline Survey dated September 25.

______. 200 4a. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 98

. July 9.

______. 2004 b

. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA) 658

. September 1

.

______. 2004 c

. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA) 698

. September 28

.

______. 2004 d

. No Furt her Action Concurrence Letter for Temporary Accumulation Area (TAA) 779 . September 7.

______. 2005a. No Further Investigation Concurrence Le tter for Group I Potential Release Locations (PRLs). July 13.Final Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

13 

### ______. 2005b. No Further Investigation Concurrence Letter for Group II Potential Release Locations (PRLs). November 2.

______. 2009a. No Further Investigation Concurrence with Final Summary Rep ort for Group V Potential Release Locations (PRLs). February 4.

California Regional Water Quality Control Board (RWQCB), Santa Ana Region. 1995. No Further Action Concurrence Letter for Former UST 372B. December 11.

______ 1996. No Further Action Concurre nce Letter for Former UST 126. March 12.

______ 1997 a

. No Further Action Concurrence Letter for Former UST Sites 114A, 295, 296, 435, 455, 605A, and 606A. April 11.

______. 1999a. No Further Action Concurrence Letter for UST 114B

. April 12

.

______. 1999b. No Further Action Concurrence Letter for UST 716A and OWS 716B

. April 14

.

______. 2000a. No Further Action Concurrence Letter for APHOs 25 and 50

. March 31

.

______. 2000b. No Further Action Concurrence Letter for AST 372

. August 2 8

.

______. 2003 a

. No Furth er Action Concurrence Letter for Aerial Photograph Anomaly (APHO) Sites 87, 90, 98, 99, 100, and 109. August 14.

______. 2003 b

. No Further Action Concurrence Letter for UST 204

. November 6

.

______. 2003 c

. No Further Action Concurrence Letter for OWS 658C a nd 658D

. January 8

.

______. 2003 d

. No Further Action Concurrence Letter for OWS 658E

. March 7

.

______. 2008. No Further Action Concurrence Letter for UST 206. September 10.

______. 2009. No Further Action Concurrence Letter for PRL 127

. July 23

.

______. 2011 a

. No Further Action Concurrence for AST 126 , Former Marine Corps Air Station, El Toro, Irvine, California

. June 3

.

______. 2011 b

. Closure For Petroleum Release

– Vadose Zone Soils, Former Tank 398 Site, Former Marine Corps Air Station, El Toro, Irvine , California . March 11.

______. 2011c. C omments on the Information Package, Location of Concern MSC JP5 (JP5 Pipelines ) Former Marine Corps Air Station, El Toro, (Geotracker No. T0605964530). June 17.

Department of Defense (DoD). See U

. S

. Department of Def ense.

Department of the Navy (DON). See U.S. Department of the Navy.

Ecology and Environment (e&e) 1991. Asbestos Survey and Assessment , Camp Pendleton, El Toro and Tustin, Marine Corps Air Stations, California, Volume 1 Report. December.Final Finding of Suitability to Transfer #6 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

14 

### Earth Tech

. 2003. Final Environmental Baseline Survey, Former Marine Corps Air Station, El Toro, California. September.

______. 2005 a

. Summary Report for Group I Potential Release Locations, Environmental Baseline Survey, Former Marine Corps Air Station, El Toro, Ca lifornia . February.

______. 2005b. Summary Report for Group II Potential Release Locations, Environmental Baseline Survey, Former Marine Corps Air Station, El Toro, California . March.

——— . 2008

. Final Summary Report for Group V Potential Release Locations, Environmental Baseline Survey, Former Marine Corps Air Station, El Toro, California. December

.
International Technology (IT) Corporation, 1989. Asbestos Survey and Assessment, MCAS, El Toro

. March.

Jacobs Engineering Group (JEG). 1993. Marine Corps Air St ation El Toro, El Toro, California, Installation Restoration Program, Resource Conservation and Recovery Act (RCRA) Facility Assessment Report. July

.

______. 1995. Marine Corps Air Station El Toro, El Toro, California, Installation Restoration Program, Final Environmental Baseline Survey Report

. April.

Orange County Health Care Agency (OCHCA). 1996. No Further Action Concurrence Letter for USTs 210, 212, and 214 . September 20.

______. 199 7 a. No Further Action Concurrence Letter for UST s 208, 209, 211, 21 3, 215, and T

- 6

. March 27

.

______. 1997b. No Further Action Concurrence Letter for UST T

- 9 . July 11.

______. 1998 a

. No Further Action Concurrence Letter for UST 205 and UST 207

. April 24

.

______. 1998b. No Further Action Concurrence Letter for UST 658A and UST 658B . April 24.

______. 199 8c

. No Further Action Concurrence Letter for UST 716A and OWS 716B

. July 28

.

______. 2000 a

. No Further Action Concurrence Letter for UST 372A . July 26.

______. 2000 b

. No Further Action Concurrence Letter for UST 763B and OWS 763A . July 26.

______. 2000c

. No Further Action Concurrence Letter for USTs 902A, 902B, and 902C . August 4.

______. 2000d

. No Further Action Concurrence Letter for UST T

- 7, UST T

- 8, and UST 726 . July 26.

______. 200 4

. No Further Action Concurrence Letter for UST 1 14C

. May 25

.
U.S. Department of Defense (DoD). 1994

. Asbestos, Lead Paint, and Radon Policies at BRAC Properties. Memorandum for Assistant Secretary of the Army (Installations, Logistics, and Environment); Assistant Secretary of the Air Force (Man power, Reserve Affairs, Installations, and Environment); and Director, Defense Logistics Agency. Principle Assistant Deputy Under Secretary of Defense (Environmental Security). October.Final Finding of Suitability to Transfer #7 Finding of Suitability July 2012 Former MCAS El Toro, California to Transfer

15 

### ______. 1997. Base Redevelopment and Implementation Manual

. Office of the Deputy Under Secretary of Defense (Industrial Affairs and Installations). December.

______. 2006. Base Redevelopment and Realignment Manual . Office of the Deputy Under Secretary of Defense (Installations and Environment). March.

U.S. Department of the Navy ( DON ). 1989. Memorandum for T.J. Zagrobelny, Commander, Naval Facilities Engineering Command, referencing U.S. EPA memorandum on disposal requirements for PCB small capacitors. Subject: Disposal of Fluorescent Light Ballasts Containing PCBs.

______. 1990. Southwest Division, Naval Facilities Engineering Command (SWDIV). Federal Facility Agreement between the U.S. Marine Corps, U.S. EPA Region IX, California Department of Health Services, and State Water Resources Control Board.

______. 1997. F inal Rec ord of Decision, Operable Units 2A and 3A, No Action Sites, Marine Corps Air Station El Toro, California . Southwest Division, Naval Facilities Engineering Command, San Diego, California. September 30

.

______. 2002 a

. Final Environmental Impact Statement for the Disposal and Reuse of Marine Corps Air Station, El Toro, California. March.

______. 2002 b

. Record of Decision, Disposal and Reuse of Marine Corps Air Station El Toro, California . April.

______. 2004. Final Finding of Suitability to Transfer (Parcel IV and Portions of Parcels I, II, and III), Former Marine Corps Air Station El Toro, California. July.

______. 20 08

. Final Record of Decision, Operable Unit 2C, Installation Restoration Program Sites 3 and 5, Former Marine Corps Air Station, El Tor o, California. March

.
______. 2009. Base Realignment and Closure Program Management Office. Summary Report, JP5 Building 363 Dry Well , Former Marine Corps Air Station, El Toro, California. May 27

.

____. 2011. Base Realignment and Closure Program Manageme nt Office. Information Package, Location of Concern MSC JP5 (JP5 Pipelines), Former Marine Corps Air Station, El Toro, California. April 29.

United States Environmental Protection Agency (U.S. EPA) Region IX. 1999. No Further Action Concurrence for APHO 25

. October 6

.

______. 2003. Concurrence Letter for Final Environmental Baseline Survey (EBS) dated April 2003. September 25.

______. 2005a. Concurrence Letter for Group I Potential Release Locations (PRLs). March 16.

______. 2005b

. Concurrence Letter for Group II Potential Release Locations (PRLs). April 7

.
Wiedemeier & Associates (Wiedemeier). 2007. Monitored Natural Attenuation Evaluation and Long

- Term Monitoring Plan, Former JP

- 5 Truck Fueling Area, Former MCAS El Toro, California. June.

# TABLESFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 1

Page 1 of 2 Table 1: Buildings/Structures

Carve

O ut Building/Structure Number Building/Structure/Description Year of Construction Square Feet

Carve

- Out II

- Q

II

- Q 114 Maintenance H ang a r 1966 32,921

II

- Q 124 Maintenance H angar 1943 6,240

II

- Q 125 Maintenance H angar 1943 4,224

II

- Q 126 Maintenance H ang a r 1943 4,224

II

- Q 127 Tire S torage P lant 1943 4,026

II

- Q 230 Paint L ocker 1943 78

II

- Q 231 Paint L ocker 1943 78

II

- Q 363 Petroleum, oil, and lubricants ( POL ) P ipeline S helter 1952 200

II

- Q 372 Airfield O perations / C ontrol T ower 1954 26,375

II

- Q S 396 Aircraft T ruck F ueling <1958 140

II

- Q S 558 Aircraft T ruck F ueling F acility <1973 160

II

- Q S 559 Aircraft T ruck F ueling F acility <1973 160

II

- Q S 560 Aircraft T ruck F ueling F acility <1973 160

II

- Q S 561 Aircraft T ruck F ueling F acility <1973 160

II

- Q 642 Electric P ower P lant 1969 144

II

- Q 658 Jet Engine T est ing Facility 1972 2,894

II

- Q S 659 S torage T ank n on potable water <1973 25,000 Gallons

II

- Q 677 Meteorological B uilding <1973 8

II

- Q 698 Line M aintenance S helter 1975 900

II

- Q 716 Engine Test Cell / Hush H ouse 1978 8,880

II

- Q 747 Contract R efueler F acility 1983 1,200

II

- Q 752 Fuel F arm No. 5 O ffice 1983 348

II

- Q 763 Aircraft W ashrack U tility B uilding 1984 684

II

- Q 779 Hazardous W aste C ollection F acility 1983 204

II

- Q 903 Shelter <1997 315

II

- Q S 904 Aircraft F ueling S tation <1997 800

II

- Q S905 Aircraft Fueling Station <1997 800

II

- Q S906 Aircraft Fueling Station <1997 800

II

- Q S907 Aircraft Fueling Station <1997 800

II

- Q S908 Aircraft Fueling Station <1997 800

II

- Q S909 Aircraft Fueling Station <1997 800

II

- Q S910 Aircraft Fueling Station <1997 800

II

- Q S911 Aircraft Fueling Station <1997 800

II

- Q 923 D rop T ank R inse F acility 1993 576

II

- Q 938 Vacant H azardous W aste S torehouse <1997 272

II

- Q 952 Hazardous W aste S torehouse <1997 272

II

- Q 1804 Vacant M aintenance H angar 1966 480

Source: Earth Tech 2003 and Enviro Compliance Solutions, Inc. ( ECS ) field visit and review of station records in April

201 1Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 1

Page 2 of 2 Note s: Buildings/structures that have been demolished or removed are not shown.

Acronyms and Abbreviations : ECS = Enviro Compliance Solutions, Inc. MCAS = Marine Corps Air Station POL = p etroleum, o il, and l ubricants S = s tructure

< = b efore specified yearFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 2

Page 1 of 1 Table 2: Environmental Requirements and Notifications Applicable to Property

Carve

- Out

Environmental Factors Considered I I

- F

- 1 I I

- Q I I

- V

- 1

Presence of Hazardous Substances (Notification) N Y N

CERCLA/RCRA (Response/Corrective Action) N Y N

Presence of Petroleum Products and Derivatives N Y N
UST/AST Storage Tanks (Closure/Removal) N Y N
Munitions and Explosives of Concern

– Response Actions N N N

Asbestos

- Containing Material N Y N

Lead

- Based Paint N Y N
Polychlorinated Biphenyls N Y N

P esticides (Agricultural) Y Y Y

Acronyms and Abbreviations:
AST = A boveground S torage T ank CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act MCAS = Marine Corps Air Station N = No RCRA = Resource Conservation and Recovery Act UST = u nderground s torage t ank Y = YesFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 3

Page 1 of 2 Table 3: Potential Release Locations

LOC ID Building Number/ Location Description Closure Report Title/Date NFA and NFI Letter Agency/Date Notes

Carve

- Out II

- Q

PRL 114 114 Maintenance Hangar Summary Report for Group I PRLs

February 2005 by

Earth Tech Department of Toxic Substances Control ( DTSC )

07/13/2005

U.S. E nvironmental Protection Agency (U.S. E PA )

03/16/2005 Potential Release Location ( PRL ) 114 is associated with M aintenance H angar 114

. No s i ginificant staining or other evidence of release was observed at Building 114 and its vicinity during the visual site inspection ( VSI ) in 2004

. N FI was recommeded for PRL 1 14 in the February 2005 Summary Report for Group I PRLs and regulatory concurrence was obtained.

PRL 235 235 Former Bore Sighting Range/Pistol Range Summary Report for Group V PRLs

December 2008 by

Earth Tech DTSC

02/04/2009 This facility is a former bore sighting range/pistol range. Facility has been removed. All available records were reviewed and evaluated and NFI was recommeded for PRL 235 in the December 2008 Summary Report for Group V PRLs. Regulatory concurrence on NFI was obtained

PRL 372 372 Airfield Operations/Control Tower Summary Report for Group V PRLs

December 2008 by

Earth Tech DTSC

02/04/2009 PRL 372 is associated with Building 372. Pad mounted transformers were identified with stickers indicating less than 50 parts per million polychlorinated biphenyls. No leaks or stains were observed near the transformers. NFI was recommeded for PRL 372 in the December 2008 Summary Report for Group V PRLs and regulatory concurrence was obtained.

PRL 658 658 Jet Engine Testing Facility Summary Report for Group I PRLs

February 2005 by

Earth Tech DTSC

07/13/2005

U.S. EPA

03/16/2005 PRL 658 is associated with Building 658. No investigation activities were proposed for PRL 658 based on the review of previously completed investigations and closure. NFI was recommeded for PRL 658 in the February 2005 Summary Report for Group I PRLs and regulatory concurrence was obtained.

PRL 716 716 Engine Test Cell / Hush House Summary Report for Group V PRLs

December 2008 by

Earth Tech DTSC

02/04/2009 PRL 716 is associated with Building 716. A possible release of a waste. Staining on concrete pad and nearby soil and stressed vegetation was observed during the 2004 VSI. A catch basin for stormwater is situated outside the building. Sum ps and trench drains are situated in the facility. A floor drain was identified in a former engine test cell. A hydraulic pit is situated in the facility. Soil sampling was conducted in June 2005 and based on the review of the soil sampling data, NFI was r ecommeded for PRL 716 in the December 2008 Summary Report for Group V PRLs and regulatory concurrence was obtained.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 3

Page 2 of 2 Table 3: Potential Release Locations

LOC ID Building Number/ Location Description Closure Report Title/Date NFA and NFI Letter Agency/Date Notes

PRL 747 747 Contract Refueler Facility Summary Report for Group V PRLs

December 2008 by

Earth Tech DTSC

02/04/2009 PRL 747 is associated with Building 747. Stained areas were noted within concrete berm and at certain locations surrounding concrete bermed area during 2002 VSI. Possible releases of fuel may have occurred due to fuel sampling activities conducted in the past. Soil sampling was conducted in June 2005 and based on the review of the soil sampling data, NFI was recommeded for PRL 7 47 in the December 2008 Summary Report for Group V PRLs and regulatory concurrence was obtained.

PRL 923 923 Drop Tank Rinse area runoff Summary Report for Group II PRLs

March 2005 by

Earth Tech DTSC

11/02/2005

U.S. EPA

04/07/2005 PRL 923 is associated with Building 923.This building was utilized as a drop tank rinse facility. A sump was observed in the northwestern portion of B uilding 923. Soil sampling was completed in January 2005. NFI was recommeded for PRL 923 in the March 2005 Summary Report for Group II PRLs and regulatory concurrence was obtained.

Source: Earth Tech 2003 and Review of Records by Enviro Compliance Solutions, Inc

., in April 2011

.

Acronyms and Abbreviations DTSC = Department of Toxic Substances Control EBS = e nvironmental b aseline s urvey ID = Identification LOC = l ocation of c oncern MCAS = Marine Corps Air Station N FA = n o further action NFI = n o f urther i nvestigation PRL = p otential r elease l ocation U.S. EPA = U .S. Environmental Protection Agency VSI = v isual s ite i nspectionFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 1 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

Carve

- Out I I

- F

- 1

There are no CERCLA or Petroleum locations of concern ( LOCs ) within Carve

- Out ( CO ) II

- F

- 1

Carve

- Out I I

- Q

APHO 25 Agua Chinon Wash Disturbed Ground and Excavation Summary Report, APHO 25, Mounded Material

08/10/1999 by

Naval Facilities

Engineering Command (NAVFAC)

Engineering Field

Division (EFD) Southwest (SW) California Department of Toxic Substances

Control (DTSC)

08/31/1999

U.S. EPA 10/06/1999 Regional Water Quality Control Board Santa Ana Region (RWQCB)

03/31/2000 APHO 25 is located near Agua Chinon Wash

. Historical facility records were reviewed and a Summary Report recommending NFA was submitted in 1999

. Regulatory concurrence on NFA has been obtained

.

APHO 50 Tank Farm No. 5 Disturbed Ground and Excavation Summary Report, APHO 50, Former

Trench or other Linear Feature

09/29/1999 by

NAVFAC EFD SW DTSC

11/30/1999

RWQCB

03/31/2000 APHO 50 was located near former Tank Farm 5 and Agua Chinon Wash. Historical facility records were reviewed and a Summary Report recommending NFA was submitted in 1999. Regulatory agency concurrence of NFA recommendation has been obtained.

APHO 98 372 Wet Soil Information Package, APHO 87, 90, 98, 99, 100, and 109

May 2003 by

NAVFAC EFD SW RWQCB 08/14/2003

DTSC

07/09/ 2004 Identified on a 1967 photograph. Wet soil was noted near Facility 1793 and Facility 372, and near the edge of an aircraft parking apron. There were three former fuel storage tanks located adjacent to Facility 372 (Underground Storage Tanks [USTs] 902A, 902 B, and 902C). The tanks were removed and the site was closed in 2000. NFA was recommended at Aerial Photograph Feature/Anomaly (APHO) 98, due to the proximity of this anomaly to a former fuel storage area. RWQCB and DTSC concurred with recommendation of NF A.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 2 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

APHO 100 114 Liquid Flowing Information Package, APHOs 87, 90, 98, 99, 100, and 109 May 2003 by

NAVFAC EFD SW DTSC

06/25/2003

RWQCB 08/14/2003 Identified on a 1967 photograph. Liquid was reported to be flowing from Facility 114. Facility 114 is adjacent to a former wash rack. The wash rack was evaluated and granted an NFA status in 1996. The tank (UST 763B) and Oil/Water Separator (OWS) 763A asso ciated with the wash rack have been removed and closed. NFA was recommended for APHO 100 based upon results of sampling for the wash rack and the removal of the associated tank and OWS. Based on a VSI conducted in June 2003, DTSC and RWQCB concurred with

r ecommendation of NFA.

IRP Site 4 658 Ferrocene S pill A rea ( Operable Unit [OU]

- 3 ) Final Record of Decision (ROD) , OU 2A & 3A, No Action Sites

0 9/30/1997 by

NAVFAC SW U.S. EPA, DTSC, RWQCB

0 9/30/1997 Installation Restoration Program ( IRP ) Site 4 consists of two units: Unit 1 is an oil

- stained area southeast of Building 658 which overlaps a concrete transformer pad, and Unit 2 is a drainage ditch which received runoff from a ferrocene spill. The staining at Unit 1 was the result of oily discharges from Building 658, which were observed over an approximate 2

- year period. The contamination at Unit 2 originated from an August 1983 spill, when the contents of a 500

- gallon tank (wash water and residual jet fuel) reportedly overflowed during washing and spille d onto the ground, draining into a ditch adjacent to 9th Street. The spilled liquid reportedly contained approximately 5 gallons of ferrocene and a hydrocarbon carrier solution Investigations conducted at IRP Site 4 include a Phase I Remedial Investigation (RI) and aerial photograph surveys in 1993. Volatile organic compounds (VOCs) and semi

- volatile organic compounds (SVOCs) were below residential Preliminary Remediation Goals (PRGs) in both units. The human health and ecological risk assessments showed th at the contaminants present in the soil do not present an unacceptable risk to human health or the environment. Therefore, no remedi al action was required. The ROD was signed on 30 September 1997

.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 3 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes During the RI of IRP Site 4, groundwater monitoring wells were installed near Building 658 and a release of petroleum to groundwater was detected. This release was attributed to jet fuel released from the nearby jet propulsion fuel, grade 5 ( JP5 ) pipelines at the former JP5 Truck Fueling Area ( TFA ) ; the petroleum

- impacted groundwater is known as the JP5 TFA Plume. The RWQCB has approved closure of the vadose zone soil for the Miscellaneous ( MSC ) JP5 pipeline segments and TFA features overlying the plume. An evaluation of natural attenuation of groundwater was completed in 2007, and the RWQCB concurred with monitored natural attenuation (MNA) with long

- term monitoring as the groundwater remedy on 31 August 2007. The Department of the Navy ( DON ) is conducting groundwater monitoring of the JP5 TFA Plume in accordance with the MNA remedy as required by the Monitored Natural Attenuation Evaluation and Long

- Term Monitoring Plan, Former JP

- 5 Truck Fueling Area, Former Marine Corps Air Station, El Toro, California

. ( Wiedemeier & Associates 2007).

IRP Site 25 N / A Major D rainages (OU

2A) Final ROD , OU 2A & 3A, No Action Sites 09/30/1997 by

NAVFAC SW U.S. E nvironmental Protection Agency (U.S. E PA )

, DTSC, RWQCB

09/30/1997 IRP Site 25 consisted of four drainage channels that flow through or adjacent to the Station and receive storm water discharges from the Station. Concentrations of metals, pesticides, and petroleum products below levels requiring response actions were detected at the site

. The NFA ROD was signed on 09/3 0/1997

RFA 13 114 and 115 Drop Tank Storage Area Final RFA report July 1993 by Jacobs Engineering Group (JEG) and

Final Addendum to RFA report May 1996 by Bechtal National, Inc. (BNI) DTSC

07/23/1996 NFA status was identified in the final Resource Conservation and Recovery Act (RCRA) Facility Assessment (RFA) report (JEG 1993) and regulatory concurrence obtained.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 4 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

RFA 15 N/A Wash water Runoff Site associated with Aircraft Fueling Station Final RFA report July 1993 by JEG

and

Final addendum to RFA report May 1996 by BNI DTSC

07/23/1996 W ash water runoff site situated adjacent to former JP5 Fueling Station 576. Site is inactive. NFA status identified in the final RFA report (JEG 1993) and DTSC concurred with NFA recommendation in a letter dated 07/23/96.

RFA 16 N/A Wash water Runoff Site associated with Aircraft Fueling Station Final RFA report July 1993 by JEG

and

Final addendum to RFA report May 1996 by BNI DTSC

07/23/1996 W ash water runoff sites situated adjacent to former Fueling Station 574. Site is inactive. NFA status identified in the final RFA report (JEG 1993) and DTSC concurred with NFA recommendation in a letter dated 07/23/96.

RFA 40 127 Drum Storage Area Final RFA report July 1993 by JEG

and

Final addendum to RFA report May 1996 by BNI DTSC

07/23/1996 RFA 40, a former drum storage area in the vicinity of Building 127 and RFA 41, was not located during the RFA. The site was described in a letter dated June 23, 1989. NFA was recommended in the RFA report (JEG 1993) and regulatory concurrence was obtained in a letter dated 7/23/1996.

RFA 41 127 Vehicle Wash Rack Final RFA report July 1993 by JEG

and

Final addendum to RFA report May 1996 by BNI DTSC

07/23/1996 RFA 41, a former vehicle wash rack, was located near Building 127. Soil samples were collected during the RFA Sampling Visit. NFA was recommended in the RFA report (JEG 1993), and DTSC concurred with NFA recommendation in a letter dated 07 /23/96.

RFA 210 763 Vehicle Wash Rack Final RFA report July 1993 by JEG

and

Final addendum to RFA report May 1996 by BNI DTSC

07/23/1996 Inactive vehicle wash rack. NFA status was identified in final RFA report (JEG 1993) and DTSC concurred with NFA recommendation in a letter dated 07/23/96.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 5 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

RFA 257 N/A Wash water Runoff Site associated with Aircraft Fueling Station Final RFA report July 1993 by JEG

and

Final addendum to RFA report May 1996 by BNI DTSC

07/23/1996 W ash water runoff sites near former Aircraft Direct Fueling Station 575 . Site is inactive. NFA status identified in the final RFA report (JEG 1993) and DTSC concurred with NFA recommendation in a letter dated 07/23/96.

RFA 258 N/A Wash water Runoff Site associated with Aircraft Fueling Station Final RFA report July 1993 by JEG

and

Final addendum to RFA report May 1996 by BNI DTSC

07/23/1996 W ash water runoff sites near former Aircraft Direct Fueling Station 577 . Site is inactive. NFA status identified in the final RFA report (JEG 1993) and DTSC concurred with NFA recommendation in a letter dated 07/23/96.

TAA 658 658 < 90

- day Accumulation Point Addendum to C losure R eport for Temporary Accumulation Area 658

05/27/2003 By

Shaw DTSC

09/01/2004 Temporary Accumulation Area (TAA) 658 also known as Solid Waste Management Unit (SWMU)/Area of Concern (AOC) 171. Site assessment and soil sampling was completed in March 2003. An addendum to closure report was submitted on 05/27/2003 to DTSC and DTSC concurred with the NFA recommendation in a letter dated 09/01/2004.

TAA 698 698 < 90

- day Accumulation Point Closure R eport

TAA 698

06/06/2003 By

Shaw DTSC

09/28/2004 TAA 698 also known as SWMU/AOC 252. Soil sampling was completed in February 2003. A closure report was submitted on 06/06/2003 to DTSC and DTSC concurred with the NFA recommendation in a letter dated 09/28/2004.

TAA 779 779 < 90

- day Accumulation Point Addendum to C losure R eport

TAA 779

02/05/2003 By IT Corp. DTSC

09/07/2004 TAA 779 also known as SWMU/AOC 227. Soil sampling was completed in December 2002. An addendum to closure report was submitted on 02/05/2003 to DTSC and DTSC concurred with the NFA recommendation in a letter dated 09/07/2004.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 6 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

AST 126 126 300 Gallon Oil Tank Information Package, Aboveground Storage Tank (AST) 126.
11/06/2001 by

NAVFAC EFD SW RWQCB

06/03/2011 Tank has been removed. No releases identified. The RWQCB concurred with the NFA in a letter dated 06/03/2011.

AST 372 372 275 Gallon Diesel Tank Summary Report, Former AST 372

07/24/2000 by

NAVFAC EFD SW RWQCB

08/28/2000 Tank has been removed. NFA decision by RWQCB as of 08/28/2000.

AST 658 658 200 Gallon Ferrocene Tank Information Package, AST 658 04/04/2002 by

NAVFAC EFD SW DTSC

03/10/2003 Formerly situated at Building 658 near IRP Site 4. Tank has been removed and NFA was received as of 03/10/2003.

UST 114A 114 1,500 Gallon Fuel Oil Tank Technical Memorandum, Former UST Sites 114A, 295, 296, 435, 455, 605A, and 606A

03/21/1997 by

NAVFAC EFD SW RWQCB

04/11/1997 UST removal completed on 10/11/91. Site closed by RWQCB in an NFA letter dated 04/11/97.

UST 114B 114 560 Gallon Diesel Tank Site Assessment Report, Former UST Site 114B 06/15/1998 By OHM Remediation Services, Inc. (OHM) RWQCB

04/12/1999 Removal completed on 10/11/91. Site closed by RWQCB in an NFA letter dated 04/12/99.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 7 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

UST 114C 114 600 Gallon Fuel Oil Tank Closure Report

UST 114C

04/08/2004 by Geofon, Inc. (Geofon) Orange County Health Care Agency (OCHCA)

05/25/2004 UST 114C was closed in place with OCHCA oversight on March 10, 2004. Tank contents were removed, tank closed in place, and soil samples were collected on March 10, 2004. Site closed by OCHCA in a letter dated 05/25/2004.

UST 126 126 500 Gallon Diesel Tank Site Assessment Report, UST 126 November 1995 by

BNI RWQCB

03/12/1996 UST 126 was rem oved on November 27, 1991 under the OCHCA oversight. Additional s ite assessment activities were completed in 1995. A s ite a ssessment r eport was submitted to RWQCB in November 1995. Site closed by RWQCB in a n NFA letter dated 03/12/96.

UST 204 204 50,000 Gallon Diesel Tank UST Removal Report, UST 204 10/29/1999 by

Geofon and Addendum Site Assessment Report, UST 204 09/09/2003 by

Shaw RWQCB

11/6/2003 SWMU/AOC 60. Tank was formerly within Tank Farm No. 6. Tank has been removed. All required response actions have been completed. RWQCB concurred with NFA in a letter dated 11/6/2003.

UST 205 205 25

, 000 G allon R ecovered JP5 T ank Tank C losure R eport, USTs 205 and 207

0 3/18/1998 by

OHM OCHCA

04/24/1998 SWMU/AOC 61. Tank was formerly within Tank Farm No. 6. Removal completed on 12/29/97. Site closed by OCHCA in a n NFA letter dated 0 4/24/98.

UST 206 206 50

, 000 G allon U nleaded F uel T ank Summary R eport
UST 206 July 2008 by

E nviro Compliance

Solutions, Inc. RWQCB

09/10/2008 SWMU/AOC 62. Tank was formerly within Tank Farm No. 6. UST 206 was removed on 08/31/1999. From 2000 to 2008 additional site assessment and excavation activities were completed. A Summary r eport was submitted to the RWQCB in July 2008 and RWQCB concurred with NFA in a letter dated 09/10/2008.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 8 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

UST 207 207 50

, 000 G allon U nleaded F uel T ank Tank Closure Report, USTs 205 and 207

03/18/1998 by

OHM OCHCA

04/24/1998 SWMU/AOC 63. Tank was formerly within Tank Farm No. 6. Removal completed on 01/8/98. Site closed by OCHCA in an NFA letter dated 04/24/98.

UST 208 208 50,000 Gallon Aviation Gas Tank Tank Removal Field Activities, Tank 208, 209, 211, 213, 215, and T

- 6

12/16/1996 to

12/17/1996 by American Processing OCHCA

03/27/1997 Tank was formerly within Tank Farm No. 5. Removal completed on 12/16/96. Site closed by OCHCA in an NFA letter dated 03/27/97.

UST 209 209 25,000 Gallon Aviation Gas Tank Tank Removal Field Activities, Tank 208, 209, 211, 213, 215, and T

- 6
12/16/1996 to

12/17/1996 by American Processing OCHCA

03/27/1997 Tank was formerly within Tank Farm No. 5. Removal completed on 12/16/96. Site closed by OCHCA in an NFA letter dated 03/27/97.

UST 210 210 25,000 Gallon Aviation Gas, JP5 Tank Tank Removal Closure Report for USTs at Tank Farm No. 5

08/01/1996 by Toxguard OCHCA

09/20/1996 Tank was formerly within Tank Farm No. 5. Removal completed on 06/14/96. Site closed by OCHCA in an NFA letter dated 09/20/96.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 9 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

UST 211 211 50,000 Gallon Aviation Gas Tank Tank Removal Field Activities, Tank 208, 209, 211, 213, 215, and T

- 6
12/16/1996 to

12/17/1996 by American Processing OCHCA

03/27/1997 Tank was formerly within Tank Farm No. 5. Removal completed on 12/16/96. Site closed by OCHCA in an NFA letter dated 03/27/97.

UST 212 212 50,000 Gallon Aviation Gas, JP5 Tank Tank Removal Closure Report for USTs at Tank Farm No. 5

08/01/1996 by Toxguard OCHCA

09/20/1996 Tank was formerly within Tank Farm No. 5. Removal completed on 6/14/96. Site closed by OCHCA in an NFA letter dated 09/20/96.

UST 213 213 25,000 Gallon Aviation Gas Tank Tank Removal Field Activities, Tank 208, 209, 211, 213, 215, and T

- 6

12/16/1996 to

12/17/1996 by American Processing OCHCA

03/27/1997 Tank was formerly within Tank Farm No. 5. Removal completed on 12/16/96. Site closed by OCHCA in an NFA letter dated 03/27/97.

UST 214 214 25,000 Gallon Aviation Gas, JP5 Tank Tank Removal Closure Report for USTs at Tank Farm No. 5

08/01/1996 by Toxguard OCHCA

09/20/1996 Tank was formerly within Tank Farm No. 5. Removal completed on 06/14/96. Site closed by OCHCA in an NFA letter dated 09/20/96.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 10 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

UST 215 215 50,000 Gallon Aviation Gas Tank Tank Removal Field Activities, Tank 208, 209, 211, 213, 215, and T

- 6
12/16/1996 to

12/17/1996 by American Processing OCHCA

03/27/1997 Tank was formerly within Tank Farm No. 5. Removal completed on 12/16/96. Site closed by OCHCA in an NFA letter dated 03/27/97.

UST 372A 372 2,000 Gallon Diesel Tank UST removal report, UST 372A 6/12/2000 by

Geofon OCHCA

07/26/2000 Removal completed on 02/28/00. No evidence of a release was identified. Site closed by OCHCA in an NFA letter dated 07/26/00.

UST 372B 372 2,500 Gallon Diesel Tank Site assessment report, UST 372 8/1995

by

BNI RWQCB 12/11/1995 Removal completed on 02/28/94. Site closed by RWQCB in an NFA letter dated 12/11/95.

UST 398 398 108

, 000 G allon JP5 T ank Information Package

Former Tank 398 Site

01/27/2011 by

DON Base Realignment and Closure (BRAC) Program Management Office (PMO) West RWQCB

03/11/2011 UST 398 was removed in 19 93. A Remedial Action Plan for MN A of groundwater and free product removal was approved by RW QCB in December 2006. A five year MNA demonstration with free product removal is on going since 2007. A Summary Information Package with NFA for vadose zone soil at former UST 398 Site was submitted on January 27, 2011 to the RWQCB. The RWQCB in a letter dated March 11, 2011 closed the vadose zone soil at former UST 398 Site. The area requiring petroleum restrictions (ARPR) for former UST 398 Site addressed in this Finding of Suitability to Transfer (FOST) affects the CO II

- Q.

UST 658A 658 10,000 Gallon JP5 Tank Tank closure report, USTs 658A and 658B

03/27/1998 by

OHM OCHCA

04/24/1998 Removal completed on 01/26/98. Site closed by OCHCA in an NFA letter dated 04/24/98.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 11 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

UST 658B 658 10,000 Gallon JP5 Tank Tank closure report, USTs 658A and 658B

03/27/1998 by

OHM OCHCA

04/24/1998 Removal completed on 1/26/98. Site closed by OCHCA in an NFA letter dated 04/24/98.

UST 716A 716 3,000 Gallon Waste Oil Tank Tank closure report, UST 716A and OWS 716B

05/13/1998 by

OHM OCHCA

07/28/1998

RWQCB

04/14/1999 SWMU/AOC 192. Tank closed in place. Site closed by OCHCA in a letter dated 07/28/98 and by RWQCB in an NFA letter dated 04/14/99.

UST 763B 763 500 Gallon Waste Oil Tank UST & OWS removal report, UST 763B & OWS 763A 6/12/2000 by

Geofon OCHCA 07/26/2000 SWMU/AOC 212. Removal completed on 02/28/00. Site closed by OCHCA in an NFA letter dated 07/26/00.

UST 902A 902 50,000 Gallon JP5 Tank UST removal report, UST 902A 7/11/2000 by

Geofon OCHCA

08/04/2000 Tank has been removed. Site closed by OCHCA in an NFA letter dated 08/04/00.

UST 902B 902 50,000 Gallon JP5 Tank UST removal report, UST 902C 7/11/2000 by

Geofon OCHCA

08/04/2000 Tank has been removed. Site closed by OCHCA in an NFA letter dated 08/04/00.

UST 902C 902 2,500 Gallon JP5 Tank UST removal report, UST 902C 7/11/2000 by

Geofon OCHCA

08/04/2000 Tank has been removed. Site closed by OCHCA in an NFA letter dated 08/04/00.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 12 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

UST T

- 6 T

- 6 2,000 Gallon Waste JP5 Tank Tank Removal Field Activities, Tank 208, 209, 211, 213, 215, and T

- 6
12/16/1996 & 12/17/1996 by American Processing OCHCA

03/27/1997 SWMU/AOC 21. Associated with Tank Farm No. 5. Removal completed on 12/16/96. Site closed by OCHCA in an NFA letter dated 03/27/97.

UST T

- 7 T

- 7 2,000 Gallon Waste JP5 Tank UST Removal Report, UST T

- 7

06/12/2000 by

Geofon OCHCA

07/26/2000 SWMU/AOC 24. Associated with Tank Farm No. 6. Removal completed on 02/28/00. No evidence of a release was identified. Site closed by OCHCA in an NFA letter dated 07/26/00.

UST T

- 8 T

- 8 2,000 Gallon Waste JP5 Tank UST Removal Report, UST T

- 8

06/12/2000 by

Geofon OCHCA

07/26/2000 SWMU/AOC 22. Associated with Tank Farm No.5. Removal completed on 02/28/00. Site closed by OCHCA in an NFA letter dated 07/26/00.

UST T

- 9 T

- 9 2,000 Gallon JP5 Tank Tank Removal and Site Closure Report, UST T

- 9

06/16/1997 by

OHM OCHCA

07/11/1997 SWMU/AOC 228. Associated with Tank Farm No.6. Removal completed on 03/27/97. Site closed by OCHCA in an NFA letter dated 07/11/97.

OWS 658C 658 400 Gallon OWS Site Assessment Report, OWS 658C and 658D 12/31/1998 by

NAVFAC EFD SW RWQCB

01/08/2003 OWS installed in 1972; OWS closed in place. OWS was an underground unit and was not associated with a UST. Site closed by RWQCB in an NFA letter dated 01/08/2003.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 13 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

OWS 658D 658 1,750 Gallon OWS Site Assessment Report, OWS 658C and 658D 12/31/1998 by

NAVFAC EFD SW RWQCB

01/08/2003 OWS installed in 1995. OWS closed in place. OWS was an aboveground unit and was not associated with a UST. Site closed by RWQCB in an NFA letter dated 01/08/2003.

OWS 658E 658 10 Gallon OWS Memorandum, OWS 658E

01/23/2003 by

NAVFAC EFD SW RWQCB

03/07/2003 OWS was removed and backfilled in November 2002. Soil samples were taken during this removal action. Site closed by RWQCB in an NFA letter dated 03/07/2003.

OWS 716B 716 100 Gallon OWS Tank Closure Report, UST 716A and OWS 716B

05/13/1998 by

OHM OCHCA

07/28/1998

RWQCB

04/14/1999 Site also identified as SWMU/AOC 193. OWS was installed in 1976. OWS has been removed. OWS was associated with UST 716A. Site was investigated and recommended for NFA by the RFA based on the results of soil sampling. Site closed by OCHCA in a letter dated 07/28/98 and by RWQCB in an NFA letter dated 04/14/99.

OWS 763A 763 100 Gallon OWS UST & OWS Removal Report, UST 763B & OWS 763A

06/12/2000 by

Geofon OCHCA

07/26/2000 Site also identified as SWMU/AOC 211. OWS installed in 1982. OWS has been removed. OWS was associated with UST 763B. Site was investigated and NFA was recommended in the RFA based on soil sample results. No significant soil contamination was identified at this site. Site closed by OCHCA in an NFA letter dated 07/26/00.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 14 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

MSC JP5 CO

- II

- Q Fuel Pipelines and Associated Truck

Fueling Areas Closure Report

MSC JP5 Units 1 and 3

06/26/2001

by OHM

Information Package MSC JP5 Pipelines

04/29/2011 by

DON BRAC PMO West RWQCB

06/17/2011 The JP5 pipelines and all associated TFA features within CO II

- Q are inactive. Pipelines have been abandoned in place. Pipeline segments and associated features were separately inv estigated and closed by the RWQCB. NFA concurrence was obtained for all the segments of MSC JP5 pipelines and associated TFA features from the RWQCB.

The groundwater plume underlying the MSC JP5 pipelines segments and associated TFA encompasses the area be neath f ormer Tank Farm No. 5 , f ormer Tank Farm No. 6 , the former TFA, and IRP Site 4. The RWQCB has closed the vadose zone soil for the MSC JP5 pipeline segments and TFA features overlying the p lume. An evaluation of natural attenuation of groundwater was completed in 2007, and the RWQCB concurred with m onitored natural attenuation as the groundwater remedy on 31 August 2007. The ARPR for MSC JP5 pipeline and associated TFA plume addressed in this FOST affects the CO II

- Q.

PRL 127 127 Tire Storage Plant Summary Report for PRL 127

05/15/2009 By DON, BRAC PMO WEST RWQCB

07/23/2009 Building 127 was a former propeller shop with floor drains and trench drains in the facility. A wash rack, RFA 41 was associated with the operations. During the 2005 EBS update VSI visit, petroleum impacted soils were identified in a small area southwest o f Building 127. In 2009, exploratory excavation and soil sampling was completed. A Summary Report was submitted to RWQCB on 05/15/2009 and Potential Release Location (PRL) 127 was closed by RWQCB in a letter dated 07/23/2009.

PCB T14 114 Transformer Pad Final EBS 09/12/2003 by

Earth Tech DTSC 09/25/2003

U.S. EPA 09/25/2003 Replaced with a non

- polychlorinated biphenyl (PCB) transformer. A 1994 field survey indicates no evidence of release. No PCB releases identified through the records search or VSIs condu cted for the 2003 EBS.

PCB T20 125 Transformer Pad Final EBS 09/12/2003 by

Earth Tech DTSC 09/25/2003

U.S. EPA 09/25/2003 Replaced with a non

- PCB transformer. A 1994 field survey indicates no evidence of release. No PCB releases identified through the records search or VSIs conducted for the 2003 EBS.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 15 of 16 Table 4: Locations of Concern

LOC ID Building Number/ Location Description Closure Report Title/Date NFA Letter Agency/Date Notes

PCB T21 125 Transformer Pad Final EBS 09/12/2003 by

Earth Tech DTSC

09/25/2003

U.S. EPA 09/25/2003 Replaced with a non

- PCB transformer. A 1994 field survey indicates no evidence of release. No PCB releases identified through the records search or VSIs conducted for the 2003 EBS.

PCB T58 372 Transformer Pad Final EBS 09/12/2003 by

Earth Tech DTSC

09/25/2003

U.S. EPA 09/25/2003 Replaced with a non

- PCB transformer. A 1994 field survey indicates no evidence of release. No PCB releases identified through the records search or VSIs conducted for the 2003 EBS.

PCB T60 378 Transformer Pad Final EBS 09/12/2003 by

Earth Tech DTSC

09/25/2003

U.S. EPA 09/25/2003 Replaced with a non

- PCB transformer. A 1994 field survey indicates no evidence of release. No PCB releases identified through the records search or VSIs conducted for the 2003 EBS.

PCB T89 658 Transformer Pad Final EBS 09/12/2003 by

Earth Tech DTSC

09/25/2003

U.S. EPA 09/25/2003 Replaced with a non

- PCB transformer. A 1994 field survey indicates no evidence of release. No PCB releases identified through the records search or VSIs conducted for the 2003 EBS.

PCB T94 716 Transformer Pad Final EBS 09/12/2003 by

Earth Tech DTSC

09/25/2003

U.S. EPA 09/25/2003 Replaced with a non

- PCB transformer. No evidence of release observed during 1994 field survey. No PCB releases identified through the records search or VSIs conducted for the 2003 EBS.

PCB T109 Tank Farm No. 6 Transformer Pole Final EBS 09/12/2003 by

Earth Tech DTSC

09/25/2003

U.S. EPA 09/25/2003 Building demolished; no evidence of release observed during 1994 field survey. No PCB releases identified through the records search or VSIs conducted for the 2003 EBS.

Carve

- Out I I

- V

- 1

There are no CERCLA or Petroleum LOCs within CO II

- V

- 1

Acronyms and Abbreviations

AOC = area of c oncern APHO = a erial p hotograph feature/ a nomaly ARPR = area requiring petroleum restrictions AST = aboveground storage tank BNI = Bechtel National , Inc. I T Corp. = IT Corporation JEG = Jacobs Engineering Group JP5 = j et p ropulsion f uel, g rade 5

< = less than LOC = l ocation of c oncern MCAS = Marine Corps Air Station RCRA = Resource Conservation and Recovery Act RI = r emedial i nvestigation RFA = RCRA f acility a ssessment ROD = Record of Decision RWQCB = Regional Water Quality Control Board

= S anta Ana RegionFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 4

Page 16 of 16 BRAC = Base Realignment and Closure CERCLA = Comprehensive Environmental Response,

= Compensation, and Liability Act C O = C arve

- O ut DON = Department of the Navy DTSC = California Department of Toxic Substances

= Control EBS = e nvironmental b aseline s urvey E FD = En gineering Field Division F OST = finding of suitability to transfer Geofon = Geofon, Inc. ID = i dentification IRP = in stallation r estoration p rogram M NA = m onitored natural attenuation MSC = miscellaneous N/A = not applicable NAVFAC = N aval Facilities Engineering Command NFA = n o f urther a ction OCHCA = Orange County Health Care Agency OHM = OHM Remediation Services

, Inc. OU = o perable u nit OWS = oil/water separator PCB = polychlorinated biphenyl P MO = Project Management Office PRG = preliminary remediation go al PR L = potential release location S VOC = semi

- volatile organic compounds S W = southwest SWMU = s olid w aste m anagement u nit TAA = t emporary a ccumulation a rea T F A = truck fueling area UST = underground storage tank U.S. EPA = United States Environmental Protection Agency VSI = visual site inspection VOC = volatile organic compoundFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 5

Page 1 of 2 Table 5 : Summary of Asbestos Surveys

Building Number Description Square Feet Year Built Historical Asbestos Survey Information Comments

Carve

- Out II

- Q

114 Maintenance Hang a r 32,921 1966 IT Corp oration (IT Corp.) [ 1989 ] : Floor tile, transite, pipe insulation. CABACO/Tait Environmental Management, Inc. ( CABACO/Tait ) ; (6/15/99): Stucco, pipe elbows, floor tile & mastic, window putty, boiler flue, exterior mastic, wall panels, drywall joint compound Non

- friable, acessible, and damaged ( FAD ) asbestos

- containing material ( ACM ) found.

124 Maintenance Hangar 6,240 1943 CABACO/Tait ( 10 / 15 /99): Stucco Non

- FAD ACM found; no interior ACM observed.

125 Maintenance Hangar 4,224 1943 IT Corp

. (1989): Floor tile. CABACO/Tait (7/ 22 /99): Stucco, cement ceiling (assumed) Non

- FAD ACM found.

126 Maintenance Hangar 4 ,224 1943 IT Corp

. ( 1989 ) : No ACM Found No ACM found.

127 Tire Storage Plant 4 ,026 1943 IT Corp

. ( 1989 ) : No ACM Found No ACM found.

230 Paint Locker 78 1943 IT Corp

. ( 1989 ) : No ACM Found No ACM found.

231 Paint Locker 78 1943 IT Corp

. ( 1989 ) : No ACM Found No ACM found.

363 P etroleum, Oil, and Lubricants (P OL ) Pipeline Shelter 200 1952 Ecology & Environment, Inc. ( e&e ) [ 1991 ] : No ACM Found No ACM found.

372 Airfield Operations /Control Tower 26,375 1954 IT Corp

. ( 1989 ) : Transite, vibration dampener, pipe insulation, floor tile. CABACO/Tait (6/15/99): Ceiling panels, drywall joint compound, floor tile & mastic, pipe insulation, duct connectors (assumed), cement panels (assumed). Non

- FAD ACM found.

642 Electric Power Plant 144 1969 e&e ( 1991 ) : No ACM Found No ACM found.

658 Jet Engine Test ing Facility 2

, 894 1972 e&e ( 1991 ) : Floor tile, noise and fireproofing panels Non

- FAD ACM found.

677 Meteorological Building 8 <1973 e&e ( 1991 ) : No ACM Found No ACM found.

698 Line Maintenance Shelter 900 1975 e&e ( 1991 ) : Floor tile, roofing Non

- FAD ACM found.

716 Engine Test Cell / Hush H ouse 8,880 1978 e&e ( 1991 ) : Floor tile, fireproofing panels. CABACO/Tait (10/15/99): Floor tile mastic Non

- FAD ACM found.Final Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Table 5

Page 2 of 2 Table 5 : Summary of Asbestos Surveys

Building Number Description Square Feet Year Built Historical Asbestos Survey Information Comments

747 Contract Refueler Facility 1

, 200 1983 IT Corp

. ( 1989 ) : No ACM Found No ACM found.

752 Fuel Farm No. 5 Office 348 1983 e&e ( 1991 ) : Roofing Non

- FAD ACM found; no interior ACM observed.

1804 Vacant Maintenance Hangar 480 1966 e&e ( 1991 ) : Floor tile Non

- FAD ACM found.

MSC JP5 Portions of the Miscellaneous ( MSC ) Jet Propulsion Fuel, Grade 5 ( JP5 ) pipeline Unknown Many segments

<1960.

Some segments Unknown. Department of the Navy ( DON ) [ 200 9 ] : pipeline outer tar coating A sample of the black tarry coating on a segment of the JP5 pipeline near the JP5 Building 363 Dry Well was analyzed for asbestos in order to characterize the coated pipeline for disposal. The sampling activity is not considered similar to an asbestos survey for buildings or structures. The sampling activity is included in Table 5 in order to disclose the presence of asbestos in the coating

. Non

- FAD ACM found

. Source: Earth Tech 2003 and Review of Records by E nviro Compliance Solutions, Inc., in 2011.

Notes: The information presented in this table was obtained from the listed source. Acronyms and Abbreviations ACM = a sbestos

- containing material CABACO /Tait = CABACO /Tait Environmental Management, Inc. DON = Department of the Navy e&e = Ecology & Environment , Inc. FAD = friable, accessible, and damaged IT Corp

. = IT Corporation JP5 = jet propulsion fuel, grade 5 MCAS = Marine Corps Air Station MSC = Miscellaneous POL = p etroleum, o il, and l ubricants

< = before specified yearFinal Finding of Suitability to Transfer # 7 July 2012 Former MCAS El Toro, California Table 6

Page 1 of 1 Table 6 : Monitoring Wells

Carve Out Well ID Purpose

Carve

- Out II

- Q (Figure 6 )

II

- Q 03LYS1 Leachate Monitoring

II

- Q 04UGMW63 Groundwater Monitoring

II

- Q 04 DGMW66A Groundwater Monitoring

II

- Q ASMW398

- 01 Groundwater Monitoring

II

- Q ASMW398

- 02 Groundwater Monitoring

II

- Q MW398

- 01R Groundwater Monitoring

II

- Q MW398

- 4 Groundwater Monitoring

II

- Q MW398

- 6 Groundwater Monitoring

II

- Q MW398

- 12 Groundwater Monitoring

II

- Q MW398

- 13 Groundwater Monitoring

II

- Q MW398

- 17 Groundwater Monitoring

II

- Q MW398

- 19D Groundwater Monitoring

II

- Q MW398

- 21R Groundwater Monitoring

II

- Q MW398

- 26 Groundwater Monitoring

II

- Q MW398

- 28 Groundwater Monitoring

II

- Q MW398

- 29 Groundwater Monitoring

II

- Q MW398

- 30 Groundwater Monitoring

II

- Q MW398

- 31 Groundwater Monitoring

II

- Q RW398

- 01 Groundwater Monitoring

II

- Q RW398

- 02 Groundwater Monitoring

II

- Q TF6MW

- 01 Groundwater Monitoring

II

- Q TF6MW

- 02 Groundwater Monitoring

II

- Q TFAMW

- 01 Groundwater Monitoring

II

- Q TFAMW

- 02 Groundwater Monitoring

II

- Q TFAMW

- 03 Groundwater Monitoring

Source:
Earth Tech 2003
E nviro Compliance Solutions, Inc. Field Visit and Records Review in April 2011.

Accronyms and Abbreviations :

ASMW = Air Sparge Monitoring Well DGMW = Downgradient Monitoring Well
ID = Identification LYS = Lysimeter MCAS = Marine Corps Air Station MW = Monitoring Well RW = Recovery Well UGMW = Upgradient Monitoring Well TF = Tank Farm TFA = Truck Fueling Area

# FIGURES

### Figure 1 Vicinity Map Finding of Suitability to Transfer (FOST #7) Former MCAS El Toro, California Source: Final Environmental Baseline Survey, Former Marine Corps Air Station El Toro, California. Earth Tech 2003 

# 3 Former MCAS El Toro Project Location



### P A C I F I C O C E A N

0 10 20 5 MilesIII-B-330 0.5 10.25MilesIII-B-3II-HII-F-1II-V-1II-QII-DII-CSource:Final Environmental Baseline Survey,Former Marine Corps Air StationEl Toro, California. Earth Tech 2003FinalJuly 2012Figure 2Carve-Out Areas Location MapFinding of Suitability to Transfer (FOST #7)Former MCAS El Toro, CaliforniaLegendCarve-Out Area (FOST #7)Leased Area (Carve-Outs)RoadsProperty BoundaryTransferred AreasNon-leased Navy PropertySite 1II-V-2II-F-2II-F-3II-F-1II-F-2II-F-3!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!A!AFinalJuly 2012Figure 3Carve-Out II-F-1Finding of SuitabilitytoTransfer (FOST #7)Former MCAS El Toro, CaliforniaSource:Final Environmental Baseline Survey,Former Marine Corps Air StationEl Toro, California. Earth Tech 20033II-F-10 400 800200FeetLegendCarve-Out Area (FOST #7)RoadsNavy Retained PropertyProperty BoundaryII-F-2[_[_[_[_!=!=!="/"/"/#0#0#0#0#0#0#0$1$1$1$1$1$1$1$1")#*#*#*#*#*APHO 98APHO 100APHO 50APHO 25PRL 747PRL 716PRL 658[_[_[_#0PCB T21

M S C J P 5 I R P S i t e 2 5 - A g u a C h i n o n W a s h

M S C J P 5

M

S

C

J P

5 M

S

C

J P

5IRP Site 4Unit 1IRP Site 4Unit 2642372677779903S904S9062311241141804952698S558363S560752125S561763S907S905S910S911S908S909230S559747S396938923S659658126127716PRL 127[_#0UST 398UST 209UST 208UST 211UST 210UST 213UST 215UST 212UST 214UST T-6UST T-8UST 204UST T-7UST 207UST 205UST 206UST T-9UST 126UST 114CUST 902CUST 902BUST 902AUST 372BUST 372AUST 658BUST 658AUST 763BUST 114BUST 716AUST 114ARFA 258RFA 15RFA 210RFA 40RFA 41RFA 13RFA 257RFA 16AST 126AST 372AST 658PRL 372PRL 923PRL 114PRL 235PCB T60PCB T58PCB T94PCB T14PCB T109PCB T20PCB T89TAA 658TAA 698TAA 779OWS 658EOWS 658COWS 658DOWS 763AOWS 716B")")")")")")")")")")")")")")")")")")")")")")")")")")")FinalJuly 2012Figure 4Carve-Out II-QFinding of SuitabilitytoTransfer (FOST #7)Former MCAS El Toro, CaliforniaSource:Final Environmental Baseline Survey,Former Marine Corps Air StationEl Toro, California. Earth Tech 20033II-QII-Q0 300 600150FeetLegendCarve-Out Area (FOST #7)BuildingRoadsMiscellaneous (MSC) JP5[_Potential Release Location (PRL)$1RCRA Facility Assessment (RFA) Site#0Polychlorinated Biphenyl (PCB)Transformer/Equipment#*Oil/Water Separator (OWS)!=Temporary Accumulation Area (TAA)")Underground Storage Tank (UST)"/Aboveground Storage Tank (AST)Aerial Photograph Anomaly (APHO) AreaInstallation Restoration Program (IRP) Site124StructureS907II-V-1II-F-1II-V-2II-F-2LegendCarve-Out II-V-1 (FOST #7)Navy Retained PropertyProperty BoundaryRoadsFigure 5Carve-Out II-V-1Finding of SuitabilitytoTransfer (FOST #7)Former MCAS El Toro, CaliforniaSource:Final Environmental Baseline Survey,Former Marine Corps Air StationEl Toro, California. Earth Tech 20033FinalJuly 2012II-V-10 400 800200FeetII-V-2!A!A!A04UGMW63TFAMW-01TFAMW-03MW398-01RMW398-28!ATFAMW-02!ARW398-02!AMW398-30!A!A!AMW398-31!AMW398-4RW398-01!AASMW398- 02TF6MW-01TF6MW-02S561FORMER UST 398 GROUNDWATERPLUME AREA WITH BUFFER ZONEMSC JP5 PIPELINES AND ASSOCIATEDTFA GROUNDWATER PLUME AREA WITHBUFFER ZONE230S559779126127716S904S905S910S911S908S909S906S907938II-QMW398-6MW398-21RMW398-17MW398-1304DGMW66AMW398-26MW398-12ASMW398-01MW398-2903LYS1MW398-19D!A!A!A!A!A!A!A!A!A!A!A!A!A!A372658698763747363952S560S558S396752923S6591141251246771804642903231FinalJuly 2012Figure 6Carve-Out II-QExisting Buildings/Structures and WellsFinding of Suitability to Transfer (FOST #7)Former MCAS El Toro, CaliforniaSource:Final Environmental Baseline Survey,Former Marine Corps Air StationEl Toro, California. Earth Tech 200330 300 600150FeetII-QLegend!AMonitoring Well (MW)Carve-Out Area (FOST #7)BuildingRoadsArea Requiring Petroleum Restrictions(ARPR)658TFA Truck Fueling AreaMSC MiscellaneousStructureS907UST Underground Storage TankJP5 Jet Propulsion Fuel, Grade 5

# A TTACHMENT 1

COMMENTS/RESPONSE TO COMMENTSJuly 25 , 2012 **Response s**  **to Comments** Page 1 of 9
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Comments in E

- mail Dated: June 12, 2012.

Comment No. Section/ Page No. Comment Response

1 a

. Table 5 MSC JP5 Pipeline Table 5

– Summary of Asbestos Surveys: A new entry for MSC JP5 was added at the bottom of the Table. The entry is rather confusing. The description in Column 2 indicates it is for portions of the MSC JP5 pipeline. This pipeline runs throughout Carve

- Out ( CO) II

- Q. However, the 2009 reference listed in Column 5 is specifically for a “Summary Report, JP5 Building 363 Dry Well, ...” Please explain the relationship between the JP5 Building 363 Dry Well and the MSC JP5 pipeline. A segment of the JP5 pipeline di scharged fuel from fuel filter units and truck fueling stations in to a dry well, known as the JP5 Building 363 Dry Well. During the excavation of petroleum

- impacted soils from the JP5 Building 363 Dry Well, a segment of the JP5 pipeline was exposed and re moved. The pipeline was coated with a black tarry or bituminous coating . A sample of the coating was analyzed for asbestos in order to characterize the coating for disposal of the pipeline segment . The test results were presented in the “Summary Report, J P5 Building 363 Dry Well...”.

The Comments column of Table 5 will be revised to add a comment stating: “A sample of the black tarry coating on a segment of the JP5 pipeline near the JP5 Building 363 Dry Well was analyzed for asbestos in order to characteriz e the coated pipeline for disposal. The sampling activity is not considered similar to an asbestos survey for buildings or structures. Th e sampling activity is included in Table 5 in order to disclose the presence of asbestos in the coating .”

1b

. Table 5 Table 5 also lists Building 363 (Petroleum, Oil, and Lubricants (POL) Pipeline Shelter) as having been surveyed in 1991 and no ACM was found. Please explain the relationship between the Building 363 (POL Pipeline Shelter) entry and the MSC JP5 entry that references the JP5 Building 363 Dry Well. The JP5 Building 363 Dry Well was a feature or component of the Location of Concern (LOC) known as MSC JP5, identified in Table 4. The JP5 Building 363 Dry Well was located approximately 40 feet north of Buildin g 363, and the dry well was a subsurface rectangular wood

- framed feature , approximately 4 feet square and 3.5 feet deep. The dry well was filled with gravel and cobbles to a depth of 3.5 feet below ground surface. JP5 pipelines from the fuel filtering syst em and the original JP5 Truck Fueling Area Stations 363A through 363D discharged into the dry well.July 25 , 2012 **Response s**  **to Comments** Page 2 of 9
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Comments in E

- mail Dated: June 12, 2012.

Comment No. Section/ Page No. Comment Response

1c

. Table 5 Building 363 (POL Pipeline Shelter) is shown on Table 1 but the JP5 Building 363 Dry Well is not. Please explain. The JP5 Building 363 Dry Well is not included in Table 1 because it is neither a building nor a structure. The JP5 Building 363 Dry Well is a feature or component of the LOC known as MSC JP5, identified in Table 4.July 25 , 2012 **Response s**  **to Comments** Page 3 of 9
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Comments in E

- mail Dated: June 12, 2012.

Comment No. Section/ Page No. Comment Response

1d

. Table 5 What is the condition of the outer tar coating on the MSC JP5 pipeline? Was there a release of asbestos containing material (ACM) into the environment? Were soil samples taken from around the MSC JP5 pipeline and tested for asbestos? The non

- friable black tarry coating on the MSC JP5 pipeline was observed to be in good condition in several exploratory trenches and excavations. S oil samples for asbestos analysis were not collected from the soil surrounding the MSC JP5 pipeline.

During May 2006, Lennar Communities (Heritage Fie lds LLC) received Department of the Navy ( DON ) and regulatory agency approval on Project Environmental Review Form (PERF) No. ET002 Rev 1 to remove approximately 2,250 linear feet of the Norwalk

- El Toro JP5 pipeline located northeast of Irvine Boulevard. The pipeline was coated with a non

- friable black tarry substance containing chrysotile asbestos . The pipeline was removed by Lennar , and f ollowing the removal of the pipeline, thirteen (13) soil samples were collected from the bottom of the pipe trench at 300

- foot intervals and analyzed for asbestos content using United States Environmental Protection Agency (EPA) M ethod 600/R

93/116. No as bestos fibers were detected in the soil samples ( Final Supplemental Environmental Baseline Survey Report for On

- Station Portion of the Defense Fuel Supply Point Norwalk El Toro Pipeline, Former Marine Corps Air Station El Toro, California

, Enviro Complianc e Solutions, Inc. (ECS) June 2008 )

. The black coating on the pipeline that was removed according to PERF ET002 Rev 1 appears similar to the coating on segments of the MSC JP5 pipeline within CO II

- Q. Based upon the results of sampling associated with PERF ET002 , it is unlikely that a release of asbestos to the environment has occurred along the MSC JP5 pipelines within CO II

- Q

.July 25 , 2012 **Response s**  **to Comments** Page 4 of 9
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Comments in E

- mail Dated: June 12, 2012.

Comment No. Section/ Page No. Comment Response

1e

. Table 5 It is noted in Table 4, Locations of Concern, that the JP5 pipelines are inactive and have been abandoned in place. Why were the pipelines not removed? The JP5 pipelines were abandoned in place with the concurrence of the California Regional Water Quality Control Board ( RWQCB ), Santa Ana Region

. The pipelines were not removed due to the proximity of nearby util ity conduits and various structures

. 1f

. Table 5 The fact that MSC JP5 is now listed in Table 5 indicates that an asbestos survey was performed. Please explain exactly what was surveyed for asbestos (i.e., MSC JP5 pipeline, Building 363 POL Pipeline Shelter, and/or JP5 Building 363 Dry Well) Table 5 includes MSC JP5 because the black tarry coating on a segment of the MSC JP5 pipeline near the MSC JP5 Building 363 Dry Well was tested and was found to contain asbestos.

1g

. Table 5 Please add MSC JP5 to Table 1, as it can be classified as a “structure”, similar to the storage tank (S659) that is listed in Table 1. Please also make any other necessary changes to the FOST as a result of adding MSC JP5 to Table 1. T he MSC JP5 pipelines are not listed as s tructures in Table 1 because the MSC JP5 pipelines are part of the LOC known as MSC JP5, identified in Table 4.

2

. Section 2 Property Description: CO II

- Q currently refers to Figure 4; however, Figure 6 should be referenced since it is the figure titled “Carve

- Out II

- Q Existing Buildings/Structures and Wells”. Section 2, Carve

- Out ( CO ) II

- Q will be revised to refer to both Figure 4 and Figure 6.

3

. Section 4 Page 4, PRL 127: Paragraph 3 says “Table 3 identifies and provides the status of the PRLs within the COs as indicated on Figure 4.” This statement is not correct because PRL 127 has been removed from Table 3 even though PRL 127 is shown on Figure 4. Please correct the
statement. T he t ext on Section 4, Page 4, will be revised as follows: ”Table 3 and Table 4 identif y and provide the status of the PRLs within the C O s as indicated on Figure 4.”

4

. S ection 4.1.2 IRP Site 4: Since the new paragraph discusses the JP5 TFA plume, please make a reference to Figure 6 and the restrictions in Section 5.1 (similar to the reference made for MSC Sites in Section 4.2.2). The following s entence will be added at the end of Section 4.1.2 : “Figure 6 shows the location of the JP5 TFA Plume, and Section 5.1 summarizes restrictions related to petroleum products and its derivatives.”July 25 , 2012 **Response s**  **to Comments** Page 5 of 9
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Comments in E

- mail Dated: June 12, 2012.

Comment No. Section/ Page No. Comment Response

5

. Section 4.3 Asbestos

- Containing Material: Please update the last paragraph to reflect the addition of the MSC JP5 Pipelines. The last paragraph of Section 4 .3 will be revised to
state that “A total of 17 non

- residential buildings within CO II

- Q have been surveyed and the coating on a segment of the MSC JP5 pipeline within CO II

- Q has been sampled for ACM”.

6

. Section 4.4 Lead

- Based Paint: Please add “and structures” after each “building” encountered in this section except where it has already been done. The words “and structures” will be added to appropriate sentences within Section 4.4.

7

. Section 4.6 Pe sticides: This notification applies to all the property proposed for transfer under this FOST, as does footnote (c) in Attachment 4a. However, Table 2 only shows the pesticide notification for COs II

- F

- 1 and II

- Q, and not CO II

- V

- 1. Please provide consi stency between Section 4.6, Attachment 4a, and Table 2. Table 2 will be revised to include the pesticide notification for CO II

- V

- 1

.July 25 , 2012 **Response s**  **to Comments** Page 6 of 9
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Comments in E

- mail Dated: June 12, 2012.

Comment No. Section/ Page No. Comment Response

8

. Section 5.1.1 Carve

- Out II

- Q (Figure 6): Beginning with the second sentence, DTSC proposes the following re

- write to this section (Since DTSC has not seen the “RWQCB Covenant”, please ensure DTSC’s proposed language is consistent with the RWQCB Covenant): “Therefore, land use restrictions for these petroleum plume areas will be incorporated into and implemented thro ugh two separate legal instruments: (1) a quitclaim deed between the DON and the transferee and (2) a Covenant and Environmental Restriction on Property (CERP) (hereinafter referred to as the RWQCB Covenant) between the DON and the RWQCB.

In order to li mit the exposure to petroleum and its derivatives and to maintain the integrity of the corrective action until corrective action is complete, the RWQCB Covenant will restrict the following activities within the ARPR as shown on Figure 6 without prior revie w and approval from the DON and RQWCB:”

The four bulleted items would stay the same and the last (single sentence) paragraph in this section should be deleted. Also, please add “CERP” to the list of acronyms. Section 5.1 will be revised as follows (beginning with the second sentence):

“Therefore, land use restrictions for these petroleum plume areas will be incorporated into and implemented through two separate legal instruments: (1) a quitclaim deed between the DON and the transferee and (2) a Covenant and Environmental Restriction on Property (CERP) (hereinafter referred to as the RWQCB Covenant) between the DON and the RWQCB.

In order to limit the exposure to petroleum and its derivatives and to maintain the integrity of the corre ctive action until it is complete, the RWQCB Covenant will restrict the following activities within the area requiring petroleum restrictions (AR PR ) as shown on Figure 6 without prior review and approval from the DON and RW Q CB:”

The last sentence after the four bullets will be deleted

. CERP will be added to the list of acronyms and abbreviations.

9 a. Section 5.2 Asbestos

- Containing Material: Please update the first paragraph to reflect the MSC JP5 Pipelines. The text of Section 5.2 will be revised to include the MSC JP5 Pipelines within CO II

- Q

.July 25 , 2012 **Response s**  **to Comments** Page 7 of 9
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Comments in E

- mail Dated: June 12, 2012.

Comment No. Section/ Page No. Comment Response

9 b. Section 5.2 Please include a new restriction for the MSC JP5 Pipelines. Notification pertaining to asbestos

- containing material (ACM) on the MSC JP5 Pipelines has been provided in Table 5. The text of Section 5.2 will be revised to include MSC JP5 Pipelines.

9 c. Section 5.2 The last sentence in this section says the restriction applies to all buildings and structures located within C O II

- Q. However, the first paragraph in this section says the restriction only applies to ACM that has been identified with the respective COs. The two sentences are not consistent with each other. Please explain. The first sentence of Section 5.2 will be revised to be consiste nt with the last sentence. The first sentence will be changed to: “The transferee will be required to comply with the specific restrictions listed below for ACM that has been identified within CO

- II

- Q”.

1 0

. Section 6 Adjacent Properties, 3rd Paragraph: In the first sentence, CO II

- F

- 1 should be singular. In the second sentence, “adjoin” should be “adjoins” and CO II

- V

- 1 does not adjoin CO II

- F

- 2. In other words, the second sentence should read “The CO II

- V

- 1 adjoins DON retaine d CO II

V

- 2 which is associated with ..... remediation (Figure 2)”. The two sentences will be revised as follows:

“ CO II

- F

- 1 adjoins DON retained CO II

- F

- 2 and CO II

F

- 3. ” And “ The CO II

- V

- 1 adjoins DON retained CO II

V

- 2 which is associated with IRP Site 1 and IRP Site 2 groundwater plumes undergoing remediation (Figure 2). ”

1 1 a. Section 7 Covenants: 2nd Paragraph: The second quotation is not a direct quote from CERCLA. DTSC suggests that the quotation marks are removed and some text removed such th at the sentence would read as “The covenant will warrant that all remedial action necessary to protect human health and the environment with respect to any hazardous substance remaining on the property has been taken before the date of transfer and that ... “ The second quotation in the 2 nd paragraph of Section 7 will be revised as follows : “The covenant will warrant that all remedial action necessary to protect human health and the environment with respect to any hazardous substance s remaining on the property has been taken before the date of transfer and that ... “July 25 , 2012 **Response s**  **to Comments** Page 8 of 9
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Comments in E

- mail Dated: June 12, 2012.

Comment No. Section/ Page No. Comment Response

1 1 b. Section 7 This section is specifically for the CERCLA warranties. Please remove the last two paragraphs which were recently added. The last two paragraphs of Section 7 will be removed as requested

.

1 2

. Table 1 Buildings/Structures: Storage tank S659 is listed as (containing) non potable (liquid). Was this liquid water or something else? If it was something else, please explain and ensure its inclusion in the approp riate table(s). Does it have a coating that contains asbestos? According to historical facility records, Storage T ank S659 was constructed prior to 1973, was used for storage of non

- potable water , and was associated with the fire protection system. The tank has a painted exterior surface that is not suspected of containing asbestos

.

1 3

. Table 4/Page 4 of 18 Carve

- Out II

- Q, APHO 25: It appears that “Agua Chinon Wash” was changed to “Agua ChinonWash ”. Plea se confirm and explain the change Table 4 will be corrected to use Agua Chinon Wash.

1 4

. Figures All Figures are dated April 2012. Please update the figures in the Final FOST document. The figures will be updated to the appropriate month and year when FOST #7 is finalized.

1 5

. Figure 3 Please ensure that the boundary between II

- F

- 1 and II

- F

3 is drawn such as the MSC JP5 is entirely excluded from II

- F

- 1. The CO II

- F

- 1 boundar y shown on Figure 3 was verified to be correct and does exclude the LOC known as MSC JP5.

1 6 a. Figure 4 Please provide the figure in the 11”x17” format in the Final FOST document. The F inal FOST #7 will include an 11” x 17” copy of F igure 4.

1 6 b. Figure 4 The blue triangle representing OWS 763A can barely be

seen. Please correct. The blue triangle representing OWS 763A will be modified to improve its visibility , as requested

.
1 7 a. Figure 6 In the legend, please include “(ARPR)”. The acronym ARPR will be added in the legend and throughout the Final FOST #7

.

1 7 b. Figure 6 If applicable, please include “WITH BUFFER ZONE” in each of the plume titles. The words “WITH BUFFER ZONE” will be included with each of the plume titles.July 25 , 2012 **Response s**  **to Comments** Page 9 of 9
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Comments in E

- mail Dated: June 12, 2012.

Comment No. Section/ Page No. Comment Response

1 8

. Attachment 2 Unresolved Comments: Please also include DTSC’s original comment on Schools Notification (August 19, 2011) and the DON’s response in the attachment. The DTSC ’s original comment dated August 19, 2011 and the DON’s response will be included in Attachment 2.

19 a. Attachment 4a IRP 4 is associated with a petroleum release an d the 4th column only lists Ferrocene. Please confirm that there were no other petroleum contaminants detected. Also the last column should have an “R” instead of a “D”. The 4th column will be revised to include “Ferrocene and oily discharges from Building 658 ” . The last column will be corrected to “R”.

19 b. Attachment 4a UST 716A lists “D” in the last column but Attachment 4b lists “S”. Please explain the discrepancy. The reference to UST 716A in t he last column of Attachment 4a will be corrected to “ S ”

.

19 c. Attachment 4a Why is MSC JP5 not listed in this attachment? RFA 15 is included in this attachment and the hazardous substance listed is JP5. There are many examples of this type of occurrence. Please check the attachment for accuracy. MSC JP5 is not listed in Attachment 4a because it stored JP5. MSC JP5 is listed in Attachment 4b. Attachments 4a and 4b will be checked for accuracy.Ju ly 1 7 , 2012 **Response s**  **to Comments** Page 1 of 1
Document Title :

Pre

- Final F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( May 17, 2012 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, Supplemental Comments in E

- mail Dated: June 21 , 2012.

Comment No. Section/ Page No. Comment Response

1 a

. Section 7, Covenants Please change the first sentence of the 2 nd paragraph to read “The deed for transfer of CO II

- Q on which ... ” The comment will be incorporated.

1b. Section 7, Covenants Please change the last sentence of the 1 st paragraph to read “This covenant shall not apply to ... required on the COs that is ... ” The comment will be incorporated.

1c. Section 7, Covenants Please change “COs” in the last sentence of the 2 nd paragraph to “the CO”. The comment will be incorporated and the word “CO” will be used in place of “COs”.

2

. Section 5.1.1 Section 5.1.1: Please change “the former UST 398 and the former TFA site”, encountered in a couple of places in the bottom half of the first paragraph, to “the former UST 398 and MSC JP5 pipelines with associated TFA sites”. The comment will be incorporated and the names of the sites will be revised in response to the comment.

3

. Section 5.1.1 In DTSC’s Comment #9 on the Pre

- Final FOST #7 dated 6/12/12, the last acronym of the RWQCB (in DTSC

suggested text for Section 5.1.1) was misspelled as “RQWCB”. Please use the correct spelling of the acronym in the final version of the FOST. The comment will be incorporated and the correct spelling of the acronym RWQCB will be used in the text of Section 5.1.1.November 22, 2011 **Response to Review Comments** Page 1 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

1. General Were lead

- based paint surveys conducted for any of the buildings or structures associated with this FOST #7? If so, what were the findings? No lead

- based paint (LBP) surveys were conducted for buildings, structures, or facilities associated with Finding of Suitability to Transfer (FOST) #7

.

S ection 4.4 will be revised in response to the comment

. The following paragraphs will replace the existing paragraphs in Sec tion 4.4 :

“Notification of potential lead

- based paint (LBP) at buildings is based on the age of construction (i.e., constructed before the Consumer Product Safety Commission’s 1978 ban on LBP for residential use)

. Carve

- out (CO) II

- Q contains buildings , structures, or facilities that were constructed prior to 1978 and, therefore, suggests the likelihood that LBP may be present. This in turn creates the possibility that, through the action of normal weathering and maintenance, there may be lead from LBP in the soil surrounding th ese buildings. Construction dates for each of the buildings in CO II

- Q are summarized in Table 1. There are no buildings, structures, or facilities located in CO II

- F

- 1 or CO II

- V

- 1.

In order to address the risk of adverse health effects to children fr om LBP exposure, legislation and national policy regarding LBP has focused on residential areas and child

- occupied buildings/structures/facilities where children may be present. Non

- residential buildings/structures/facilities (e.g., warehouses and office b uildings) are typically occupied by adults, with minimal exposure to children.November 22, 2011 **Response to Review Comments** Page 2 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response
Non

- residential buildings/ structures/ facilities constructed prior to 1978 may not be used for residential use or child

- occupied buildings/ structures/ facilities unless the transferee performs any necessary evaluation(s) and abatement in accordance with all federal, state, and local laws and other applicable requirements. This restriction applies to all buildings, structures, or facilities located within C O II

- Q.

There are no residential buildings, structures, or facilities associated with FOST #7 , and no LBP surveys were conducted for buildings, structures, or facilities associated with FOST #7. The Department of the Navy (DON) will not conduct LBP evaluations at non

residential buildings, structures, or facilities prior to transfer. See Section 5.3 for restrictions. ”

The text of Section 5.3 will be revised in response to the comment to provide the following restriction:

“ Non

- residential buildings/ structures/ facilities constructed prior to 1978 may not be used for residential use or child

- occupied buildings/ structures/ facilities unless the transferee performs any necessary evaluation(s) and abatement in accordance with all federal, state, and local laws and other applicable requirements. This restriction applies to all buildings, structures, or facilities located within CO II

- Q.”November 22, 2011 **Response to Review Comments** Page 3 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

2. General The MCAS El Toro Finding of Suitability to Lease (FOSL) (July 2004) contains a pesticide notification (Section 4.1.9). The following paragraph is only the first notification of five notifications from that FOSL:

“Agricultural areas are present on the FOSL areas. The land that former MCAS El Toro occu pies was used for agricultural purposes prior to its development for military purposes in the early 1940s. There are 32.4 acres of agricultural property within two carve

- outs (28.7 acres within Carve

- out II

- F and 3.7 acres within Carve

- out II

- Q). The fol lowing discussion provides notifications that are required based on previous use of pesticides and herbicides at these areas.”

FOST #7 does not include a similar notification. Please include a pesticide notification in Section 4, Table 2, and Attachmen t 4a. Former agricultural areas are present within COs II

- F

- 1 and II

- Q. Table 2 and Attachment 4a have bee n updated to include pesticides, and Section 4 has been revised to include a new subsection 4.6 for pesticides with the following text:

4.6 Pesticides The Transferee is hereby notified that the property may contain pesticide residue from pesticides that have been applied in the management of the property. The Navy knows of no use of any registered pesticide in a manner inconsistent with its la beling and believes that all applications were made in accordance with Federal Insecticide, Fungicide, and Rodenticide Act ( FIFRA ) (7 U.S.C. Section 136, et seq.), its implementing regulations, and according to the labeling provided with such substances. I t is the Navy's position that it shall have no obligation under the covenants provided pursuant to Section 120(h)(3)(A)(ii) of the Comprehensive Environmental Response, Compensation, and Liability Act ( CERCLA ) , 42 U.S.C. Section 9620(h)(3)(A)(ii), for the remediation of legally applied pesticides.November 22, 2011 **Response to Review Comments** Page 4 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

3. General Section 5.13 of the FOSL (July 2004) included restrictions for buildings and structures that required an asbestos containing material (ACM) survey. FOST #7 indicates that there are many buildings/structures in FOST #7 that require an ACM survey because: they have never been surveyed for ACM; non friable, accessible, and damage (FAD) ACM was detected in a survey that was conducted prior to but not since 1997 (i.e., not within the last thre e (3) years of station operation); or they were surveyed for FAD ACM only and therefore, the presence of non

- FAD ACM is unknown. There is also one building classified as containing FAD ACM. FOST #7 does not include similar restrictions for those building s/structures. Please explain why the restrictions for these buildings/structures are not consistent with those restrictions outlined in Section 5.13 of the FOSL (July 2004). In response to this comment, FOST #7 Section 5 .2, CO II

- Q will be revised to rem ove the existing paragraphs and to include the following restrictions for asbestos

- containing material in buildings/ structures / facilities :

“Except for short

- term tours and emergency maintenance, access, use, or occupancy is prohibited pending either (1) completion of asbestos

- containing material ( ACM ) surveys and completion of any necessary ACM abatement by the transferee or (2) demolition by the transferee, in accordance with all applicable local, state, and federal laws and other requirements relating to asbestos or ACM. Pending completion of abatement or demolition, the transferee shall manage the ACM in accordance with all such applicable local, state, and federal laws and requirements. This restriction is applicable to all buildings/structures/facilities located with in CO II

- Q.”November 22, 2011 **Response to Review Comments** Page 5 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

4

. General Please provide the following “Schools Notification” in Section 4.0 and also include the notification in Table 2:

SCHOOL SITE CONSIDERATIONS

If, subsequent to transfer, any portions of the property found suitable to transfer by this FOST is considered for the proposed acquisition and/or construction of school properties utilizing state fundin g, a separate environmental review process in compliance with the California Education Code section 17210 et seq. will need to be conducted by the transferee and approved by DTSC (Brownfields and Environmental Restoration Program). The California Educatio n Code requires that a comprehensive evaluation of natural and manmade hazardous materials be conducted for school properties. This comprehensive evaluation requires additional investigation of hazardous materials outside the scope of CERCLA hazardous sub stances. This additional evaluation includes: legally applied pesticides and herbicides, imported fill materials, naturally occurring hazardous substances such as heavy metals (e.g., chromium, mercury, nickel), metalloids (e.g., arsenic, selenium), gases (e.g., methane, hydrogen sulfide), radioactive elements (e.g., radon gas) and naturally occurring petroleum deposits. The evaluation also includes ACM and lead based paint at concentrations that fall outside the scope of CERCLA. Any requirements associa ted with the evaluation of any property for compliance with the California Education Code are the sole responsibility of the transferee. As was the case for FOST #6, FOST # 7 was prepared in accordance with the most current Department of Navy (DON) Base Realignment and Closure ( BRAC ) Program Management Office ( PMO ) guidance for processing Findings of Suitability to Transfer or Lease (2008) ; this guidance does not require “School Site Considerations” to be included. No change s were made to the text in response to this comment.

Section 10.0

– References was revised to include the document “Policy for Processing Findings of Suitability to Transfer or Lease” (DON BRAC PMO 2008).November 22, 2011 **Response to Review Comments** Page 6 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response
Specific Comments

1. Page 5, Section 4.1.2

, Installation Restoration Program (IRP) Site 4. Based on the information provided in this section it sounds as though the No

- Further

- Action (NFA) Record of Decision (ROD) was for soil only. Is this the case? If so, what is the status of the other media (e.g., groundwater) at this site? Groundwater beneath Installation Restoration Program ( IRP ) Site 4 is impacted by the petroleum release from miscellaneous ( MSC ) JP5 pipelines associated with the former JP5 Truck Fueling Area (TFA)

.

The text of Section 4.1.2 will be revised to include the following information:

“ During the remedial investigation of IRP Site 4, groundwater monitoring wells were installed near Building 658 and former Tank Farm 5, and a release of petroleum to groundwater was d etected. This release was attributed to jet fuel release d from the nearby JP5 pipelines at the former JP5 Truck Fueling Area (TFA) ; the petroleum

- impacted groundwater is known as the JP5 TFA Plume. The Regional Water Quality Control Board, Santa Ana Region (RWQCB) has approved closure of the vadose zone soil for the MSC JP5 pipeline segments and TFA features overlying the plume. An evaluation of natural attenuation of groundwater was completed in 2007, and the RWQCB concurred with monitored natural attenuat ion (MNA) with long

- term monitoring as the groundwater remedy on 31 August 2007. The Navy is conducting groundwater monitoring of the JP5 TFA Plume in accordance with the MNA remedy as required by the Monitored Natural Attenuation Evaluation and Long

Term Monitoring Plan, Former JP

- 5 Truck Fueling Area, Former Marine Corps Air Station, El Toro, California (Wiedemeier & Associates 2007) .”November 22, 2011 **Response to Review Comments** Page 7 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

2. Page 5, Section 4.1.2

, IRP Site 25. Is there any underlying groundwater contamination at IRP Site 25 within the portion proposed for transfer? No underlying groundwater contamination at IRP Site 25 is within the portion proposed for transfer.

3. Page 8, Section 4.5, l ast paragraph

. The text indicates that “Fluorescent light ballasts manufactured before 1979 often contain PCB capacitors that may be disposed of as municipal solid waste.” DTSC PCB advisories indicate that non

- leaking PCB ballasts must be managed as a hazardous waste. DTSC recommends revising the sentence to delete “that may be disposed of as municip al solid waste.” T he t ext of the first sentence of the last paragraph of Section 4.5 has been revised as follows in response to the comment : “ Fluorescent light ballasts manufactured before 1979 often contain polychlorinated biphenyl ( PCB ) capacitors .”

4. Page 8, Section 4.5.2, 2 nd Sentence. Please state that there was no evidence of a release, consistent with the information provided in Table 4. T he t ext of the second sentence of Section 4.5.2 has been revised as follows in response to the comment : “Transformer PCB T109 was removed during UST excavation activities related to former Tank Farm 6 (DTSC 2003c and U.S. E PA 2003), and no evidence of a release has been identified at this transformer location.”November 22, 2011 **Response to Review Comments** Page 8 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

5. Pages 8 and 9, Section 5.1. Section 67391.1 of title 22 of the California Code of Regulations prohibits DTSC from considering property to be suitable for transfer to nonfederal entities pursuant to 42 United States Code section 9620(h) 3

- 4 where hazardous materials, hazardous wastes or constituents

, or hazardous substances remain at the property at levels which are not suitable for unrestricted use of land, unless an appropriate land use covenant is executed and recorded. Section 5.1 indicates that hazardous materials, hazardous wastes or constitue nts (petroleum and/or its derivatives) remain and ongoing petroleum corrective action is occurring. In order to adequately provide for the protection of human health and the environment, and in accordance with DTSC’s land use covenant regulations, title 2 2, section 67391.1, DTSC recommends that a land use covenant be put in place for all of the areas identified in this FOST #7 as areas requiring petroleum restrictions (ARPRs). DTSC will withhold further comment on this section until this comment has been addressed. The f ormer Tank Farm 555 area within CO II

- F

- 1 is part of an on

- going MNA petroleum corrective action for groundwater being overseen by the RWQCB. The RWQCB approved closure of the petroleum release to vadose zone soils on 26 January 2011. The Navy is coordinating with Orange County Health Care Agency (OCHCA) to close the tank structures in place. The boundary of CO II

- F

- 1 was revised to exclude the f ormer Tank Farm 555 area from FOST #7 as shown on the revised Figures 2, 3, and 6. The tex t, tables and attachments have also been revised to exclude the former Tank Farm 555 from FOST #7. The former Tank Farm 555 will be addressed as CO II

- F

- 3 in a future FOST.

The RWQCB has concurred with MNA as the groundwater petroleum corrective action f or the petroleum

- impacted groundwater at the former UST 398 and the MSC JP5 pipelines associated with the former Truck Fueling Area (TFA) in CO II

- Q. The RWQCB approved closure of the petroleum releases to the vadose zone soils at former UST 398 and the T FA on 11 March 2011 and 17 June 2011, respectively. These sites are petroleum

- only sites and there are no CERCLA hazardous substances present in the vadose zone or groundwater. The Navy is conducting long

- term groundwater monitoring of the petroleum plume s at the former UST 398 and the former TFA in accordance with the MNA Long

- Term Monitoring Plans , and the restrictions described in S ection 5.1 will enable the Navy to complete the MNA petroleum corrective action. No changes to Section 5.1, CO II

- Q will be made in response to this comment.November 22, 2011 **Response to Review Comments** Page 9 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

6. Page 10, Underground Storage Tanks (USTs) 547 to 551. What is the condition of the outer black tar coating on each of the USTs? Was there a release of asbestos containing material to the environment? Were soil samples taken from around the USTs and tested for asbestos? Why were the USTs not removed? The CO boundary of Parcel II

- F

- 1 has been revised to exclude the f ormer Tank Farm 555 area from FOST #7. T he text, tables, figures, and attachments of FOST #7 will be revised accordingly.

7. Page 10, Section 5.2.2, Building 124. The reference listed here shows (CABACO/Tait 1999b). Page 13 lists the date of this document as October 15, 1999. Table 5, Column 5 lists the date of this document as 7/22/99. Please reconcile. The reference date of October 15, 1999 is correct and Table 5, Column 5 has been revised in response to the comment as “10/15/99.”

8. Page 10, Section 5.2.2, Buildings 114, 125 and 372. Similarly, the 1999 reference listed here and on page 13 does not match the reference listed in Table 5 for Building 125. Please reconcile. Table 5 reference date for Building 125 has been revised in response to the comment as “7/15/99.”

9. Page 10, Section 5.3.2. There are several buildings and structures that were constructed prior to 1997 according to Table 1. Unless it is known that they were constructed after the Consumer Product Safety Commission’s 1978 ban on lead based paint for residential use, they should be listed in Section 5.3.2. Th ere is also one structure constructed prior to 1958 and several other structures built prior to 1973 according to Table 1. Why are those structures not listed in Section 5.3.2? The restrictions in Section 5.3 have been revised in response to this comment

. See response to general comment 1.November 22, 2011 **Response to Review Comments** Page 10 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

10. Page 11, Section 7. The last sentence is not consistent with Sections 4.1.3 and 4.2.3, which state that there are no CERCLA/RCRA or petroleum related locations of concern (LOCs) in CO II

- V

- 1. Why is CO II

- V

- 1 not identified as CERCLA 120 (h)(4) property with the appropriate covenant [CERCLA 120 (h)(4)(D)(i)]? The text in Section 7 will be revised for CO II

- F

- 1 and CO II

- V

- 1 in response to the comment as follows:

“ The deed for transfer of CO II

- F

- 1 and CO II

- V

- 1 on which there has been no release or disposal of hazardous substances or petroleum products or petroleum derivatives, and for which required regulatory concurrence as to such status has been obtained, will include a covenant made pursuant to CERCLA Secti on 120(h)(4)(D) (i) . Such covenant will warrant that any response action or corrective action found to be necessary after the date of transfer shall be conducted by the U.S. This covenant shall not apply to any response action or corrective action required on the property that is a result of an act or omission of the transferee. ”

11. Page 11, Section 8. If CO II

- V

- 1 is identified as CERCLA 120 (h)(4) property, the CERCLA 120 (h)(4)(D)(ii) access clause should be added to this section. The CERCLA 120 (h)( 4)(D) (i) covenant will apply to CO II

- F

- 1 and CO II

- V

- 1. Please see response above for comment 10.

12. Page 16, Section 10, 11 th
reference. Why is a draft final listed rather than a final document? The draft final document became the final document in accordance with S ection 7.9 of the Federal Facility Agreement for MCAS El Toro

.

13. Table 4, Page 4 of 17, IRP Site 4 and IRP Site 25, Column 4. Why is a draft final listed rather than a final document? Please see response above for comment 12.November 22, 2011 **Response to Review Comments** Page 11 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

14. Table 4, Page 4 of 17, IRP Site 4, Column 6, 2 nd Paragraph. Based on the information provided in this paragraph it sounds as though the NFA ROD was for soil only. Is this the case? If so, what is the status of the other media (e.g., groundwater) at thi s site? Please see response to specific comment number 1.

15. Table 4, Page 7 of 17, AST 126, Columns 5 and 6. Reference to the DTSC site closure concurrence is missing. This is not consistent with what is listed on page 6 in Section 4.2.2 for AST 126. Please reconcile. The text on page 6 of Section 4.2.2 for AST 126 has been revised in response to the comment and for consistency with the information presented in Table 4 as follows : “AST 126 received site closure concurrence (RWQCB 2011c).”

16. Table 4, Page 14 of 17, Oil/Water Separators (OWSs) 658C and 658D, Columns 5 and 6. The NFA letter dates (01/08/2003) are not consistent with the date listed in the references section on page 14 (January 18, 2003). Please reconcile. The reference on page 14 has been revised as follows in response to the comment ; “2003d. No Further Action Concurrence Letter for OWS 658C and 658D . January 8.”

17. Table 4, Page 17 of 17, Acronyms and Abbreviations. Please add “DON” to the list Table 4 has been revised to incorporate the comment.

18. Table 5, Building 125, Column 5. The CABACO/Tait (7/22/99) reference is missing from Section 10, page 13. Please correct. Section 10 has been revised to incorporate the reference.November 22, 2011 **Response to Review Comments** Page 12 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

19. Figures 3 and 6, Legend. In the Note, please change “will remain in place” to “were abandoned in place” for consistency with page 1. The Note refers to USTs 547 to 551 within the former Tank Farm 555. The boundary of CO II

- F

- 1 was revised to exclude the former Tank Farm 555 from FOST #7. Figures 3 and 6 ha ve been revised to delete the Note and to revise the boundary of CO II

- F

- 1 to exclude the f ormer Tank Farm 555 area from FOST #7

.

20. Figures 6 and 7. Why are USTs shown on Figure 6, but no USTs/ASTs are shown on Figure 7? Figures 3 and 6 ha ve been revised to exclude the f ormer Tank Farm 555 area from CO II

- F

- 1

. There are no remaining buildings, structures, or facilities within the revised CO II

- F

- 1. Figure 7 also presents all the existing structures that are still in place within CO II

- Q and there are no USTs/ASTs remaining within CO II

- Q

. F or that reason

, no USTs/ ASTs are shown on Figure 7

.
21. Attachment 4a, Column 9

. Please explain where this information came from and how it was determined that activities conducted at the various locations were either “not determined”, “storage”, “disposal”, or “release”. It is possible that more than one activity (“storage”, “disposa l”, and/or “release”) was conducted at a location. Where applicable, please indicate if more than one activity was determined to be conducted. Please ensure that each of the “activity(s)” listed is accurate. The information in Attachment 4a, column 9 came from the agency concurred Final Finding of Suitability to Lease, for Carve

- Outs within Parcel I, II, and III, Former Marine Corps Air Station, El Toro, California (DON July 2004)

. The information was reviewed for accuracy, and the f ollowing revisions will be made to t he activity (s) listed in column 9 of Attachment 4a:

“ TAA 658, AST 658, TAA 698, and TAA 779 activities in column 9 have been revised to ‘ S ’

- Storage."

22. Attachment 4a, Page 1 of 4, PRL 127. Column 8 shows “Unknown

- 1999”, but Attachment 4b shows “Unknown”. Please correct the inconsistency. Attachment 4b for PRL 127 has been revised as “Unknown

– 1999” in response to the comment.November 22, 2011 **Response to Review Comments** Page 13 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

23 Attachment 4a, Page 2 of 4, PRL 372. Column 4 shows “fuel oil”, but Table 3 discusses “PCBs”. Also, Column 8 shows “Unknown

- 1999”, but Attachment 4b shows “1954

- 1999 . “ Please correct the inconsistencies. Attachment 4a and Attachment 4b have been revised in response to the comment. Attachment 4a, page 2 of 4, column 4 for PR L 372 has been revised for consistency with Table 3 information for PRL 372 to show PCBs rather than fuel oil. Attachment 4b has been revised to delete PRL 372 since PRL 372 is not a petroleum site.

24. Attachment 4a, Page 2 of 4, AST 658. Column 8 shows “Unknown

- 1999”, but Attachment 4b shows ”Unknown

- 2002”. Please correct. Attachment 4b for AST 658 has been revised to show “Unknown

- 1999” in response to the comment.

25. Attachment 4b, Column 5. Please explain where this information came from and how it was determined that activities conducted at the various sites were either “not determined” or “storage”. Please also explain why none of the activities listed in Attachment 4b were identified as “release” and/or “disposal.” For example, FOST #7, Table 4, indicates that a release and/or disposal occurred at USTs 547 to 551 but Attachment 4b does not. Please ensure that each “activity(s)” listed for the various sites is accurate. The information in Attachment 4b, column 5 came from the Final Finding of Suitability to Lease, for Carve

- Outs within Parcel I, II, and III, Former Marine Corps Air Station, El Toro, California dated 2004

. The information presented in Table 4 and Attachment 4b was verified in response to the comment. The purpose of A ttachment 4b is to provide notification related to types of petroleum products that were stored within each CO. Table 4 provides relevant information related to the history and closure status of each L ocation of Concern

. The CO boundary of Parcel II

- F

- 1 h as been revised to exclude the former Tank Farm 555 area FOST #7. Therefore, the text, tables, figures, and attachments will be revised accordingly.

26. Attachment 4b

. USTs 549 and 553 are missing from the list. Please
correct. The CO boundary of Parcel II

- F

- 1 has been revised to exclude the former Tank Farm 555 area from FOST #7. Therefore, the text, tables, figures, and attachments will be revised accordingly.November 22, 2011 **Response to Review Comments** Page 14 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

27. Attachment 4a Please ensure the notification language in 40 Code of Federal Regulations part 373.3 is prominently displayed on Attachment 4a. In response to the comment, t he following notification language from the 40 Code of Federal Regulation s part 373.3 will be included in Attachment 4a under Notes: “The information contained in this N otice is required under the authority of regulations promulgated under S ection 120(h) of the Comprehensive Environmental Response, Compensation , and Liability Ac t (CERCLA or “Superfund”) 42 U.S.C. S ection 9620(h).”

Editorial Comments

1. Table 3, Page 1 of 3, PRL 372, Column 6. Please delete the extra punctuation at the end of the paragraph. Table 3 , page 1 of 3, PRL 372, column 6 has been revised in response to the comment.

2. Table 4, Page 5 of 17, RFA 15, Column 6, Line 1. Please make “site” plural. The word “site” has been changed to “sites” in Table 4

, page 5 of 17, RFA 15, column 6, line 1 has been revised in response to the comment.

3. Table 4, Page 5 of 17, RFA 16, Column 6. In line 1 please make “site” plural. In line 2, please insert the correct punctuation after “574”. The word “site” has been changed to “sites” in and the correct punctuation mark has been added after “574” in Table 4 , page 5 of 17, RFA 16, column 6 , line 1 in response to the comment.

4. Table 4, Page 6 of 17, RFA 257, Column 6, Line 1. Please make “site” plural. The word “site” has been changed to “sites” in Table 4

, page 6 of 17, RFA 257, column 6, line 1 in response to the comment

.

5. Table 4, Page 6 of 17, RFA 258, Column 6, Line 1. Please make “site” plural. The word “site” has been changed to “sites” in Table 4

, page 6 of 17, RFA 258, column 6, line 1 in response to the comment

.November 22, 2011 **Response to Review Comments** Page 15 of 15
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

6. Table 4, Page 8 of 17, UST 126, Column 6, Line 1. Please correct the spelling error. The word “removed” has been correctly spelled in Table 4 , page 8 of 17, UST 126, column 6, line 1 in response to the comment

.April 1 9

, 2012 **Response to Review Comments** Page 1 of 4
Document Title : Response to Comments Package on the D raft F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( Navy November 22, 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, E

- mail Message With Comments Dated: January 20, 2012.

Comment No. Section/ Page No. Comment Response

1. General Comment (GC) #1 DTSC's comment was simply to ask if lead

- based paint surveys were conducted and if so what the results of the surveys were. While the Navy provided a response to DTSC's comment, DTSC did not expect the language used in the draft FOST #7 to change from language agreed to in previous FOSTs. DTSC requests that the Navy keep the language used in the draft FOST unchanged with the exception of adding information about the lead

- based pai nt surveys. The comment will be incorporated , and the text of Section 4.4 and Section 5.3 will be revised as follows:

1 st paragraph of Section 4.4: “Notification of potential LBP at buildings is based on the age of construction (i.e., constructed before the Consumer Product Safety Commission’s 1978 ban on LBP for residential use). CO II

- Q contains buildings and structures that were constructed prior to 1978 and, therefore, suggests the likelihood that LBP may be present. This in turn creates the possibili ty that, through the action of normal weathering and maintenance, there may be lead from LBP in the soil surrounding these buildings. Construction dates for each of the buildings in CO II

- Q are summarized in Table 1. There are no buildings or structures lo cated in CO II

- F

- 1 or CO II

- V

- 1.”

3 rd paragraph of Section 4.4 : “ There are no residential buildings or structures associated with FOST #7. No LBP surveys were conducted for buildings and structures associated with FOST #7. See Section 5.3 for restriction s.”April 1 9

, 2012 **Response to Review Comments** Page 2 of 4
Document Title : Response to Comments Package on the D raft F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( Navy November 22, 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, E

- mail Message With Comments Dated: January 20, 2012.

Comment No. Section/ Page No. Comment Response

1 Response to Comment 1 (continued).

Paragraphs 5.3.1 and 5.3.2 will be replaced with the following paragraph:

“ Non

- residential buildings and structures constructed prior to 1978 (Table 1) may not be used for residential use or child

- occupied buildings and structures unless the transferee performs any necessary evaluation(s) and abatement in accordance with all federal, state, and local laws and other applicable requirements. This restriction applies to all buildings and structures located with in CO II

- Q (Table 1). ”April 1 9

, 2012 **Response to Review Comments** Page 3 of 4
Document Title : Response to Comments Package on the D raft F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( Navy November 22, 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, E

- mail Message With Comments Dated: January 20, 2012.

Comment No. Section/ Page No. Comment Response

2. GC #3 Similarly, DTSC is fine with the format in previous FOSTs concerning asbestos and prefers that the Navy use the previous format. The comment will be incorporated , and the text of Section 5.2 will be revised as follows:

2 nd paragraph of Section 5.2. Paragraphs 5.2.1 and 5.2.2 will be replaced with the following text:

“Except for short

- term tours and emergency maintenance, access, use, or occupancy is prohibited pending either (1) completion of ACM surveys and completion of any necessary ACM abatement by the transferee or (2) demolition by the transferee, in accordance with all applicable local, state, and federal laws and other requirements relating to asbestos or ACM. Pending completion of abatement or demolition, the t ransferee shall manage the ACM in accordance with all such applicable local, state, and federal laws and requirements. This restriction is applicable to all buildings and structures located within CO II

- Q.”

3

. G C #4 DTSC requests that this comment regarding school site considerations on any FOST #7 properties be placed in the "Unresolved Comments" section. The comment will be incorporated

. The school site considerations comment will be placed in the “Unresolved Comments” section in Attachment 2 of FOST #7

. 4

. Specific Comments (SC) #5 DTSC is engaged in a dialogue with the RWQCB regarding the potential need for a land use covenant at the sites with ongoing petroleum corrective action such as former UST 398 and the MSC JP5 pipelines (associated with the former Truck Fueling Area), when these sites are transferred to a non

- federal entity. DTSC will soon provide a comment on this issue. The comment was evaluated , and Section 5.1 of FOST #7 will be revised to include a description of the DON

RWQCB covenant and environmental restriction.April 1 9

, 2012 **Response to Review Comments** Page 4 of 4
Document Title : Response to Comments Package on the D raft F inding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( Navy November 22, 2011 )
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC)

, E

- mail Message With Comments Dated: January 20, 2012.

Comment No. Section/ Page No. Comment Response

5

. SC s #8 and #18 References to Building 125 in Section 5.2.2, on Page 13, and in Table 5 need to be correct and consistent. The restrictions from Section 5.2.2 are now presented in Section 5.2.

6. S C #9 SC #9: DTSC's comment still stands, i.e., there are several buildings listed in Table 1 for Carve

- Out (CO) II

- Q which should be listed in Section 5.3.2, the Navy's response to our SC # 9 not withstanding. Please also refer to GC #1 above. Section 5.3.2 has b een revised to include reference to Table 1 which lists all the buildings for CO II

- Q. Please see the response to Comment No. 1 (pertaining to GC #1 )

.

7

. SC #11 According to the Navy's response to DTSC's SC # 10, COs II

- V

- 1 and II

- F

- 1 are indeed identified as CERCLA 120(h)(4) property with the appropriate covenants pursuant to CERCLA 120(h)(4)(D)(i). As a result, Section 8 should include the access clause for COs II

V

- 1 and II

- F

- 1 pursuant to CERCLA 120(h)(4)(D)(ii). The comment will be incorporat ed . Section 8 will be revised to include the access clause for COs II

- V

- 1 and II

- F

- 1 pursuant to CERCLA 120(h)(4)(D)(ii).

8

. SC #14 The Navy's response to DTSC's SC #1 confirms that groundwater is contaminated and there is ongoing petroleum action for groundwater beneath IRP Site 4. It is not clear in the Navy's re s ponse to this comment if any information is going to be added to Table 4. DTSC requests that information about the ongoing petroleum corrective action for groundwater beneath Site 4 be added to the table. The comment will be incorporated

. Information from th e revised text of Section 4.1.2 (from the response to DTSC’s SC #1 ) will be added to Table 4 for IRP Site 4.

9

. SC #25 DTSC requests that the last sentence on Page 3 be revised to read "Attachment 4b, the Petroleum Products Notification Table, lists the locations of concern (LOCs) associated with the storage of petroleum products only". The comment will be incorporated . The last sentence of 1 st paragraph of Section 4 will be revised to read "Attachment 4b, the Petroleum Products Notification Table, lists the locations of concern (LOCs) associated with the storage of petroleum products only".November 2 2

, 2011 **Response to Review Comments** Page 1 of 1
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )

Reviewer: Thelma Estrada

, U.S. EPA Region 9

, E

- mail comment d ated: August 22 , 201 1

Comment No. Section/ Page No. Comment Response

1. Section 7 / Page 11 Covenants, the last sentence states: CO II

- V

- I was not impacted by petroleum or its derivatives, therefore, this CO shall be conveyed "as is" without a CERCLA covenant." The CERCLA covenants under 120(h) are for hazardous substances, not petroleum, so I am not sure what the DON means to say here. The text in Section 7 will be revised in order to incorporate the comment. Section 7 addresses both CO II

- V

- 1 and CO II

- F

- 1 due to rece nt changes to the CO II

F

- 1 boundary. Please see the Navy responses to DTSC specific comment s 5 and 6 for additional information pertaining to changes to the CO II

- F

- 1 boundary

. The revised text follows:

“ The deed for transfer of CO II

- V

- 1 and CO II

- F

- 1 on which there has been no release or disposal of hazardous substances or petroleum products or petroleum derivatives, and for which required regulatory concurrence as to such status has been obtained, will include a covenant made pursuant to CERCLA Sect ion 120(h)(4)(D) (i) . Such covenant will warrant that any response action or corrective action found to be necessary after the date of transfer shall be conducted by the U.S. This covenant shall not apply to any response action or corrective action required on the property that is a result of an act or omission of the transferee. ”November 22, 2011 **Response to Review Comments** Page 1 of 1
Document Title :

D raft F inding of Suitability to Transfer #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1, F ormer MCAS El Toro, California ( June 2011 )

Reviewer: John Broderick, California Regional Water Quality Control Board, Santa Ana Region. Dated August 10, 2011

Comment No. Section/ Page No. Comment Response

1. General We have reviewed the above

- referenced document, dated June 201 1 , which we received on July 5 , 201 1

. This document summarizes how the requirements and notifications for hazardous substances, petroleum products, and other regulated material within the above identified carve

- outs have been satisfied.

We have no comments on this f inding of s uitability to
t ransfer. Thank you for y our review of this document.

# A TTACHMENT 2

UNRESOLVED COMMENTSJuly 2012 **Unresolved Comments** Page 1 of 1
Document Title : Response to Comments Package on the Draft Finding of Suitability to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1. Former MCAS El Toro, California (Navy, June 2011)

Reviewer: Quang Than, Department of Toxic Substances Co ntrol, Dated: August 19, 2011

Comment No. Section/ Page No. Comment Response

1. General Comment #4 Please provide the following “Schools Notification” in Section 4.0 and also include the notification in Table 2:

SCHOOL SITE CONSIDERATIONS

If, subsequent to transfer, any portions o f the property found suitable to transfer by this FOST is considered for the proposed acquisition and/or construction of school properties utilizing state funding, a separate environmental review process in compliance with the California Education Code sec tion 17210 et seq. will need to be conducted by the transferee and approved by DTSC (Brownfields and Environmental Restoration Program). The California Education Code requires that a comprehensive evaluation of natural and manmade hazardous materials be

c onducted for school properties. This comprehensive evaluation requires additional investigation of hazardous materials outside the scope of CERCLA hazardous substances. This additional evaluation includes: legally applied pesticides and herbicides, impo rted fill materials, naturally occurring hazardous substances such as heavy metals (e.g., chromium, mercury, nickel), metalloids (e.g., arsenic, selenium), gases (e.g., methane, hydrogen sulfide), radioactive elements (e.g., radon gas) and naturally occurr ing petroleum deposits. The evaluation also includes ACM and lead based paint at concentrations that fall outside the scope of CERCLA. Any requirements associated with the evaluation of any property for compliance with the California Education Code are t he sole responsibility of the transferee. As was the case for FOST #6, FOST #7 was prepared in accordance with the most current Department of Navy (DON) Base Realignment and Closure ( BRAC ) Program Management Office ( PMO ) guidance for processing Findings of Suitability to Transfer or Lease (2008) ; this guidance does not require “School Site Considerations” to be included. No changes were made to the text in response to this comment.July 2012 **Unresolved Comments** Page 1 of 1
Document Title : Response to Comments Package on the Draft Finding of Suitab ility to Transfer (FOST) #7 for Carve

- Outs II

- F

- 1, II

- Q, and II

- V

- 1. Former MCAS El Toro, California (Navy, November 22, 2011)
Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), E

- mail Message With Comments Dated : January 20, 2012.

Comment No. Section/ Page No. Comment Response

1. General Comment #4 DTSC requests that this comment regarding school site considerations on any FOST # 7 properties be placed in the “Unresolved Comments ” section. As was the case for FOST #6, FOST #7 wa s prepared in accordance with the most current Department of Navy (DON) Base Realignment and Closure ( BRAC ) Program Management Office ( PMO ) guidance for processing Findings of Suitability to Transfer or Lease (2008) ; this guidance does not require “School Site Considerations” to be included. No changes were made to the text in response to this comment.

# A TTACHMENT 3

AGENCY CORRESPONDENC E

# Department of Toxic Substances Control

Matthew Rodriquez Secretary for Environmental Protection



### July27,2012

Mr. James Callian Deborah O. Raphael, Director 5796 Corporate Avenue Cypress, California 90630



### BRAC Environmental Coordinator Environmental Division/MCAS EI Toro Navy BRAC Program Management Office West 1455 Frazee Road, Suite 900 San Diego, California 92108-4310 Edmund G. Brown Jr. Governor



### CONCURRENCE WITH FINAL FINDING OF SUITABILITY TO TRANSFER #7 FOR CARVE-OUTS II-F-1, 

### 11-0, AND II-V-1, FORMER MARINE CORPS AIR STATION (MCAS) EL TORO, IRVINE, CALIFORNIA (SITE CODE: 400055)

Dear Mr. Callian:

The California Department of Toxic Substances Control (DTSC) has reviewed the Final Finding of Suitability to Transfer #7 for Carve-Outs /I-F-1, /I-Q, and /I-V-1, Former Marine Corps Air Station EI Taro, California (FOST #7), which was dated July 2012 and received in electronic format on July 26, 2012. FOST #7 provides environmental findings that establish Carve-Outs (COs) II-F-1, 

### 11-0, and II-V-1 as being suitable for transfer. These three COs comprise approximately 150 acres at the former MCAS EI Toro. DTSC concurs that the property associated with FOST #7 can be transferred with the specified notifications, restrictions, and covenants, and in a manner that is protective of human health and the environment.

DTSC commented on the Draft and Pre-Final versions of FOST #7 and the Navy has satisfactorily responded to the comments. Based on our review of the electronic final version, DTSC determines that the response to our comments has been adequately incorporated into the report. As a result, DTSC concurs with the FOST #7 report and accepts it as written.

® Printed on H.ecycled Paper**~.** 

### Mr. Callian July 27, 2012 Page 

### 2 of 

### 3

Thank you for providing DTSC with the opportunity to review and comment on the FOST 

## #7 report. If you have any questions about this concurrence, please contact me at 

## (714) 484-5352 or gthan@dtsc.ca.gov.

Sincerely,

Quang an Remedial Project Manager Brownfields and Environmental Restoration Program

rs/qt

cc: Content Arnold BRAC PMO West 

## 1455 Frazee Road,Suite 

## 900 San Diego, California 

## 92108

Lynn Hornecker BRAG PMO West 

## 1455 Frazee Road, Suite 

## 900 San Diego, California 

## 92108

Robert Woodings Restoration Advisory Board Co-Chair 

## 11 Teal Irvine, California 

## 92604

Marcia Rudolph Restoration Advisory Board Co-Chair 

## 24922 Muirland, 

## #139 Lake Forest, California 

## 92108

Daniel Jung City of Irvine P.O. Box 

## 19575 Irvine, California 

## 92623-9575

James Strozier Orange County Environmental Health Division 

## 1241 East Dyer Road, Suite 

## 120 Santa Ana, California 

## 92705

### Mr. Callian July 27,2012 Page 

### 3 of 

### 3

Polin Modanlou Orange County Planning 

## & Development Services Department
300 North Flower Street, 3 rd 

### Floor Santa Ana, California 92703

Mary Aycock U.S. Environmental Protection Agency, Region IX
75 Hawthorne Street, Mail Code SFD-8-1 San Francisco, California 94105-3901

John Broderick Regional Water Quality Control Board, Santa Ana Region 3737 Main Street, Suite 500 Riverside, California 92501-3348

Robert Elliott Department of Toxic Substances Control 1001 "I" Street 23 rd 

### Floor

, Sacramento, California 95182

Erika Giorgi Department of Toxic Substances Control 1001 "I" Street 23 rd 

### Floor



## , Sacramento, California 95182

Jennifer Rich Department of Toxic Substances Control 5697 Corporate Avenue Cypress, California 90630

# A TTACHMENT 4

4 a

– HAZARDOUS SUBSTANCES NOTIFICATION TABLE
4 b

– PETROLEUM PRODUCTS N OTIFICATION TABLEFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Attachment 4a

Page 1 of 4 Attachment 4 a : Hazardous Substances Notification Table

Carve

- O ut ID Building /Structure Number Area Type ID Hazardous Substances (a) (c) Reportable Quantity ( L b/year) (b) CAS Number RCRA Waste Code Dates of Operation Activities Conducted at Site
Carve

- Out II

- Q
II

- Q 114 PRL 114 Solvents N/A N/A N/A Unknown

1999 ND

II

- Q 114 APHO 100 Unknown N/A N/A N/A Unknown ND

II

- Q 114 PCB T14 PCBs N/A N/A N/A Unknown

1999 S

II

- Q 114 RFA 13 Unknown N/A N/A N/A Unknown

1999 S

II

- Q 125 PCB T20 PCBs N/A N/A N/A Unknow n

1999 S

II

- Q 125 PCB T21 PCBs N/A N/A N/A Unknown

1999 S

II

- Q 127 PRL 127 Petroleum p roducts and h azardous

substances N/A N/A N/A Unknown

1999 ND

II

- Q 127 RFA 40 Substances

a ssociated with drum storage areas N/A N/A N/A Unknown

1999 S

II

- Q 127 RFA 41 Washwater from vehicles N/A N/A N/A Unknown

1999 D

II

- Q 208 Non

- Trans 208 PCBs N/A N/A N/A Unknown

1999 S

II

- Q 235 PRL 235 Lead and o ther

m etals N/A N/A N/A Unknown

1999 ND

II

- Q 372 PCB T58 PCBs N/A N/A N/A 1954

- 1994 S

II

- Q 372 APHO 98 Unknown N/A N/A N/A Unknown ND

II

- Q 372 Non

- Trans 372 PCBs N/A N/A N/A Unknown

1999 S

II

- Q 372 PRL 372 PCBs N/A N/A N/A Unknown

1999 S

II

- Q 378 PCB T60 PCBs N/A N/A N/A 1954

- 1994 SFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Attachment 4a

Page 2 of 4 Attachment 4 a : Hazardous Substances Notification Table

Carve

- O ut ID Building /Structure Number Area Type ID Hazardous Substances (a) (c) Reportable Quantity ( L b/year) (b) CAS Number RCRA Waste Code Dates of Operation Activities Conducted at Site
II

- Q Former JP5 Fueling Station 574 RFA 16 Washwater from vehicles N/A N/A N/A Unk nown

1999 D

II

- Q Former JP5 Fueling Station 575 RFA 257 Washwater from vehicles N/A N/A N/A Unknown

1999 D

II

- Q Former JP5 Fueling Station 576 RFA 15 Washwater from vehicles N/A N/A N/A Unknown

1999 D

II

- Q Former JP5 Fueling Station 577 RFA 258 Washwat er from vehicles N/A N/A N/A Unknown

1999 D

II

- Q 658 TAA 658 Substances

a ssociated with less than 90

- day accumulation of
wastes N/A N/A N/A Unknown

1999 S

II

- Q 658 A ST 658 Ferrocene N/A N/A N/A Unknown

1999 S

II

- Q 658 O WS 658C Oil/ w ater N/A N/A N/A 1972

- 1999 S

II

- Q 658 OWS 658D Oil/ w ater N/A N/A N/A 1995

- 1999 S

II

- Q 658 OWS 658E Oil/ w ater N/A N/A N/A Unknown

1999 S

II

- Q 658 PRL 658 Waste JP5 N/A N/A N/A Unknown

1999 S

II

- Q 658 PCB T89 PCBs N/A N/A N/A Unknown

1999 S

II

- Q 698 TAA 698 Substances

a ssoc iated with

m aterials s torage N/A N/A N/A Unknown

1999 S

II

- Q 716 U ST 716A Waste o il N/A N/A N/A 1976

- 1998 S

II

- Q 716 PRL 716 Waste JP5 N/A N/A N/A Unknown

1999 ND

II

- Q 716 OWS 716B Oil/ o ily w ater N/A N/A N/A 1976

- 1988 S

II

- Q 716 PCB T94 PCBs N/A N/A N/ A Unknown

1999 SFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Attachment 4a

Page 3 of 4 Attachment 4 a : Hazardous Substances Notification Table

Carve

- O ut ID Building /Structure Number Area Type ID Hazardous Substances (a) (c) Reportable Quantity ( L b/year) (b) CAS Number RCRA Waste Code Dates of Operation Activities Conducted at Site
II

- Q 747 PRL 747 Waste fuels N/A N/A N/A Unknown

1999 ND

II

- Q 763 RFA 210 Solvents, w aste o il N/A N/A N/A Unknown

1999 D

II

- Q 763 UST 763B Waste Oil N/A N/A N/A 1982

- 1999 S

II

- Q 763 OWS 763A Oily w ater N/A N/A N/A 1982

- 1999 S

II

- Q 779 TAA 779 Substances

a ssociated with less than 90

- day accumulation of
wastes N/A N/A N/A Unknown

1999 S

II

- Q 923 PRL 923 Drop t ank r inse a rea N/A N/A N/A Unknown

1999 S

II

- Q N/A I RP 4 Ferrocene and oily discharges from

Building 658 N/A N/A N/A 1983 R

II

- Q T

- 6 UST T

- 6 Waste JP5 N/A N/A N/A 1988

- 1996 S

II

- Q T

- 7 UST T

- 7 Waste JP5 N/A N/A N/A 1988

- 1999 S

II

- Q T

- 8 UST T

- 8 Waste JP5 N/A N/A N/A 1988

- 1999 S

II

- Q T

- 9 UST T

- 9 Waste JP5 N/A N/A N/A 1988

- 1999 S

II

- Q N/A IRP 25 Substances associated with storm

wa ter discharges and

drainage channels N/A N/A N/A Unknown

1999 R

II

- Q Agua Chinon Wash APHO 25 Unknown N/A N/A N/A Unknown ND

II

- Q Tank Farm No. 5 APHO 50 Unknown N/A N/A N/A Unknown ND

II

- Q Tank Farm No. 6 PCB T109 PCBs N/A N/A N/A Unknown

199 9 SFinal Finding of Suitability to Transfer #7 July 2012 Former MCAS El Toro, California Attachment 4a

Page 4 of 4 Notes:
(a) This table was prepared in accordance with 40 Code of Federal Regulations ( CFR ) 373 .3 and 40 CFR 302.4. The information contained in this Notice is required under the authority of regulations promulgated under Section 120(h) of the Compreh ensive Environmental Response, Compensation, and Liability Act (CERCLA or “Superfund”) 42 U.S.C. Section 9620(h). The substances which do not have chemicals

- specific break down (and associated annual reportable quantity) are not listed in 40 CFR 302.4, an d therefore have no corresponding Chemical Abstracts Services (CAS) number, no regulatory synonyms, no Resource, Conservation

, and Recovery Act (RCRA) waste numbers, and no reportable quantities

. (b) Reportable Quantity For Buildings with chemical

- specific break down and associated reportable quantity, the information was obtained from the Air Emissions Source Survey, Final Submi ttal, MCAS El Toro. The reportable quantity was assumed to be the estimate of the air emissions value that was calculated based o n a quantity used during the year. For non

volatile organic compounds ( VOCs ) , the specific chemicals are listed and the quantity is unknown. (c) The Property may contain pesticide residue from pesticides that have been applied in the management of the Pr operty. The Grantor knows of no use of any registered pesticide in a manner inconsistent with its labeling and believes that all applications were made in accordance with the Fede ral Insecticide, Fungicide, and Rodenticide Act (FIFRA

– 7 U.S.C. Sec 136, e t seq.), its implementing regulations, and according to the labeling provided with such substances. It is the Grantor’s posi tion that it shall have no obligation under the covenants provided pursuant to Section 120(h)(3)(A)(ii) of the C ERCLA of 1980, 42 U .S.C. Section 9620(h)(3)(A)(ii), for the remediation of legally applied pesticides.

Sources: Earth Tech 2003, Radian 1996.
Acronyms and Abbreviations :
APHO = a erial p hotograph f eature/ a nomaly AST = aboveground storage tank CAS = Chemical Abstracts Service s CERCLA = Comprehensive Environmental Response, Compensation and Liability Act CFR = Code of Federal Regulations D = d isposal of wastes ID = Identification FIFRA = Federal Insecticide, Fungicide, and Rodenticide Act IRP = Installation Restoration Program JP5 = Jet propulsion fuel, grade 5 Lb = p ound MCAS = Marine Corps Air Station N / A = n ot a pplicable ND = o perations at site are n ot d etermined No. = number Non

- Trans = n on t ransformer PCB containing e quipment/ i tems OWS = o il / w ater s eparator PCB = p oly c hlor inated b iphenyls PRL = p otential r elease l ocation R = r elease RCRA = Resources Conservation and Recovery Act RFA = RCRA f acility a ssessment S = storage of hazardous material or waste TAA = temporary accumulation area U.S.C = United States Code UST = under ground storage tank VOCs = volatile organic compoundsFinal Finding of Suitability to Trans fer # 7 July 2012 Former MCAS El Toro, California Attachment 4b

Page 1 of 1 Attachment 4 b : Petroleum Products Notification Table
Carve

- O ut ID Area Type ID Petroleum Products* Dates of Operation Activities Conducted At Site Carve

- Out I I

- Q
II

- Q MSC JP5 JP5 Unknown

- 1999 S
II

- Q UST 114A Fuel oil 1966

- 1991 S
II

- Q UST 114B Diesel 1966

- 1991 S
II

- Q UST 114C Fuel oil 1966

- 1991 S
II

- Q AST 126 Oil Unknown

- 1999 S
II

- Q UST 126 Diesel Unknown

- 1996 S
II

- Q UST 204 Diesel 1943

- 1999 S
II

- Q UST 205 Recovered JP5 1943

- 1997 S
II

- Q UST 206 Unleaded gasoline 1945

- 1999 S
II

- Q UST 207 Unle aded fuel 1943

- 1998 S
II

- Q UST 208 Aviation gas 1943

- 1996 S
II

- Q UST 209 Aviation gas 1943

- 1996 S
II

- Q UST 210 Aviation gas, JP5 1943

- 1996 S
II

- Q UST 211 Aviation gas 1943

- 1996 S
II

- Q UST 212 Aviation gas, JP5 1943

- 1996 S
II

- Q UST 213 Aviation gas 19 43

- 1996 S
II

- Q UST 214 Aviation gas, JP5 1943

- 1996 S
II

- Q UST 215 Aviation gas 1943

- 1996 S
II

- Q AST 372 Diesel 1954

- 1999 S
II

- Q UST 372A Diesel 1954

- 2000 S
II

- Q UST 372B Diesel 1954

- 1994 S
II

- Q UST 398 JP5 1956

- 1993 S
II

- Q AST 658 Ferrocene Unknown

- 1999 S
II

- Q UST 658A JP5 1972

- 1998 S
II

- Q UST 658B JP5 1972

- 1998 S
II

- Q UST 902A JP5 1993

- 2000 S
II

- Q UST 902B JP5 1993

- 2000 S
II

- Q UST 902C JP5 1993

- 2000 S

Notes:

* Includes only petroleum products which fall within the scope of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Petroleum exclusion set forth in CERCLA Section 101(14). Source: Earth Tech 2003.

AST = aboveground storage tank CERCLA = Comprehensive Environmental Response, Compensation, and Liability A ct ID = identification JP5 = jet propulsion fuel, grade 5 MCAS = Marine Corps Air Station MSC = miscellaneous S = storage of h azardous m aterial or w aste UST = underground storage tank